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TOTAL WANT 10 MORE WELLS IN FISH SPAWNING AREA.

Oceans Not Oil comments on the TEPSA draft scoping report for Blocks 11B/12B off Mossel Bay & Plettenberg Bay

Total intends drilling 10 more wells near KingKlip, Hake, Mackerel, Anchovy, Pilchard, Herring spawning sites. It will also be adjacent to Critical Biodiversity Areas and Marine Protected Areas like the KingKlip corals full of fragile and sensitive coral species. ONO believes alternatives remain unconsidered, at a time when methane emissions from oil and gas processes account for 20% of worldwide GHG emissions and more South Africans could be employed by renewables.

Oceans Not Oil lodged our objections, comments and questions to the abovementioned ESIA. 

The objection is based on the following, inter alia:

1.    CONFLICT OF INTERESTS IN PROCEDURE

a)Please clarify how it is that Petroleum Agency South Africa has become a ‘decision making authority’ [i]on Environmental Impact Assessment processes.

b)Mr. Stephen Luger is included in the ESIA project team but is also listed as providing an ‘Independent review’ for cuttings and oil spill modelling.

2.    STAKEHOLDER ENGAGEMENT

This Draft Scoping public participation process has been shown to be deeply flawed and undemocratic. Onlinepublic participation meetings whilst strict regulations against social and physical interactions are in force is neither representative of Interested and Affected Parties (I&AP) and more significantly, marginalises communities who are most at risk. A very strong bias in favour of those privileged enough to have access to devices, data and electricty was evident and proved to be fundamentally exclusionary.

3.    NEED AND DESIRABILITY OF THE PROJECT  

Methane is a substantial contributor to climate change. 2014 estimates suggest that CHemissions from oil and gas processes account for approximately 20% of worldwide anthropogenic emissions[ii].This Draft Scoping Report 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 and is thus not fit-for-purpose.

a)The consequence of completely disregarding the contribution that offshore oil and gas exploration has to climate change is to ignore the fact that the subject of any authorization represents a significant threat to the environment and to biodiversity, not to mention the public’s constitutional right to an environment that is protected for the benefit of current and future generations. Please supply a comprehensive, public, cradle-to-grave greenhouse gas (GHG) emissions report.

b)Please supply an expected barrel delivery report showing the expected increase into South Africa’s carbon emissions, and its effects in relation to South Africa’s peak, plateau and decline commitments to the global economy.

c)How will continuous logging, reporting and assessment of emissions data be conducted?

d)How will compliance with climate targets be managed?

CH4 is a dominant component of emissions from offshore oil rigs, released as a result of gas flaring and venting, equipment leaks and evaporation losses, with concomitant emissions of COmainly due to gas flaring[ii],[iii].

a)What strategies for the mitigation is in place for the spectrum of these emissions, including fugitive emissions? A CH4budget is required.

b)An annual and public report of flaring volumes by TEPSA  is required. 

4.    ALTERNATIVES REMAIN UNCONSIDERED
It cannot be denied that the alternatives to the extraction of fossil fuels is the investigation and use of renewable energy. 

a)Please supply alternatives to this project.

5.    REPORT FOR JUNE 2014 BRULPADDA INCIDENT NOT SUPPLIED

a)Please supply an incident and/or accident report for June 2014 when drilling was halted. TEPSA is operating within the South African oceanic commons, as such the public has a right to know what occurred and why TEPSA and SLR deem there is no longer a risk of continuance.

6.    SUBSTANDARD MANAGEMENT OF ENVIRONMENTAL IMPACTS OF PETROLEUM EXPLORATION AND PRODUCTION 

There has been neither Cost Benefit Analysis nor Strategic Environmental Analysis for this application. Consequences of a blowout, or accidental release (and these happen as a matter of course during offshore operations) to tourism, fisheries and recreational industries have not been properly considered. TEPSA have failed to give any insight into their proposed Oil Spill Contingency Plan to allow stakeholders and I&APs to engage on whether or not this plan provides sufficient protection to associated tourism, fisheries and businesses which rely on a healthy marine environment.

a)Please supply an Cost Benefit Analysis for this application.

Despite numerous requests there has been no Strategic Environmental Assessment (SEA) undertaken. Considering the potential for massive pollution being present, a rigorous, independent and proactive SEA should have been undertaken to inform the environmental viability of this offshore oil and gas proposal.  Insufficient attention has been given to investigating and considering the socio-economic impacts of the exploration process.

b)Please supply a Strategic Environmental Analysis for this application.

7.    LACK OF DETAILED CONTINGENCY PLAN FOR SUBSEA AND SURFACE RELEASE 

a)An OSCP (Oil Spill Contingency Plan) must be made public during the Draft Scoping Report process for proper stakeholder and I&AP engagement.

b)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 Draft Scoping Reportshould 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. 

c)There is significant concern over timeous response to a spill given the listed mitigations and rate of flow of the Agulhas current:

i)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.

ii)TEPSA has committed to installing the capping stack within 20 days in event of a blowout. Based on these delays hundreds of kilometers of ocean could be fouled before proper response is in place.Please supply details plans for how the capping stack will be installed in high seas or extreme weather conditions.The Draft Scoping Report 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. Please make these plans public.

d)The Draft Scoping Report 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. Please make these plans public.

8.    LIABILITIES AND FINANCIAL RESPONSIBILITY FOR OIL SPILL REMEDIATION

Further to 6. the Draft Scoping Report makes no mention of what appropriate insurance safeguards TEPSA have in place for remediation against oil spills and other environmental damages. Considering the serious toll a spill would have on safe recreation at beaches, healthy habitats for wildlife, industries such as tourism and fishing, the South African taxpayer and the general public, the EIA should produce proof of these insurance safeguards and a reasonable level of fiscal readiness for long term cleanup and reparation process, in the event of a major disaster.

a)Please indicate what insurance safeguards are in place in the event of accidental release.

9.    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 Draft Scoping Report needs detailed modelling of cross-shore distribution of oil contaminants relating to beach morphodynamic terminology to help optimize beach cleanup planning.

10.     OPERATIONAL WASTE 
a)Please advise the public as to who will be contracted to manage the treatment and disposal of all drill wastes from the rig.

b)Please identify the exact methods to be used for the treatment and also disposal of toxic radioactive drill wastes, frack flowback, drill mud, all radioactive substances and related tools, instruments used in the usage of any radioactive materials.

c)Please identify the exact methods for the treatment and disposal of the drill mud.

d)Please advise as to how and where toxic and also radioactive wastes are to be treated and disposed of, and in what municipalities.

e)How will compliance to international standards for the handling, storage, disposal etc. of radioactive substances be managed.

f)Any drill cuttings’ offshore treatment and discharge to sea must be assessed in terms of impact on seafloor/ benthic community, water column biology and expected dispersion.

g)Composition of these emissions and effluents regarding their toxicity, biodegradation, polynuclear aromatic hydrocarbons content, and metals content, need to be made public. 

h)In addition, an explanation as to how these toxins will be mitigated during fish spawning periods is necessary.

i)The Draft Scoping claims that the effects of smothering are “expected to be relatively localised and to recover naturally through movement of bottom currents”. 
i)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[iv]. 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.[v]
ii)Cognisance must be taken of the hazards of drill cuttings disposal onto the seabed because they are often contaminated with drilling lubricants, synthetic-based drilling fluids (SBFs) and other non-aqueous drilling fluids (NAFs). The Scoping Report must include mitigation against sediments contaminated with petroleum products, heavy metals and salts, which do not biodegrade and can accumulate in high concentrations affecting reproduction of marine life, and biomagnify toxic substances in the food chain.

11.         CONTROLLED-SOURCE ELECTROMAGNETIC (CSEM) SURVEYING

On page 46: 6.4.1 Controlled Source Electro-Magnetic Survey (CSEM): it reads: “It should be pointed out that CSEM does not generate any noise as would be associated with traditional 2D and 3D seismic surveys but rather emits an electromagnetic field”. In addition, in Table 8-2, CSEM impacts are listed as “minor negative interactions”.

a)     This is both conflicting and inaccurate information. It is documented that the equipment, materials, and activities with potential to affect various elements of the marine ecosystem, using CSEM surveys include:

  1. Noise emissions 
  2. Light emissions
  3. Accidents such as small oil spills (flotation fluids)
  4. Source emissions (electro magnetic)
  5. Electrolysis at the electrodes (chlorine emission).

It is imperative that each of these are investigated, specifically in terms of the proposed CSEM activities. 

b)Many of the Sharks and Rays in South Africa are listed as Threatened and Endangered in SA waters. Please provide a summary of the species known to occur within the proposed project area (and surrounds), including their current 2020 IUCN status (for the subequatorial African region, not global listing), and which South African endemic species occur within the area and at what depth ranges.

c)There have been no baseline studies in South Africa on the effects of CSEM surveys onElasmobranchs. Elasmobranchs which are the principal group of electroreceptive fishes in the marine environment would be impacted by anthropogenic electromagnetic activities. These impacts on the sharks, rays, skates and chimeras must be thoroughly investigated.

Given the above unknown impacts on sharks, please clarify the implications of CSEM on the different individual shark species, keeping in mind that most SA shark species are IUCN and/or ToPS listed differently and therefore should be mitigated differently. Please comment on offsets and how the various levels of priority threatened species will be determined and mitigated.

d)Some marine animals have highly developed electroreceptive organs and most likely can detect electro magnetic emissions. Some animals may use naturally occurring electromagnetic information to navigate while others may use the information to detect less visible prey at close range. Elasmobranchs have been shown to detect prey at close range particularly in areas of low visibility, using their Ampullae of Lorenzini which can detect weak electric currents in seawater. In addition, sharks and rays are known to exhibit avoidance responses, behavioural responses and threshold responses to electro magnetic disturbances.

Some animals use electric or magnetic fields for navigational purposes. How will this be mitigated?

e)Please provide a full explanation of the energy attenuation and diffusion equation of electromagnetic energy. Please explain in lay-mans terms,  not in jargon.

f)Please indicate the zone of influence and time of influence under which the CSEM surveys have.

g)Please elaborate on the specifics of the electrolysis which will occur during the CSEM’s, highlighting the specifics of the chemistry involved, as well as the electrode material/s which will be used. In addition, please specify the impacts to the site and into the water column of the chemistry as a result of the CSEM surveys.

12.    SEISMIC NOISE AND PRESSURE EMISSIONS 

The Vertical Seismic Profiling, which involves airguns capable of inducing lethal and sublethal injuryxi,xii. 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:

a)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.

b)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.

c)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.

d)Inclusion of the impact of multibeam bathymetric sonar in the mitigation measures must be made. Ocean depth, multibeam echo sounders sweep a swath up to 7.4 times water depth and so affect a wide area. Potential impacts on marine mammals may range from physical damage, including gross damage tears and the ‘bends’, temporary and permanent threshold shift (deafness), to perceptual (masking biologically significant noises) and behavioural impacts (temporary or permanent displacement and stress) as well as indirect effects (reduced prey availability) (Gordon et al.,1998). High intensity, low and mid-frequency sonar has been implicated in some fatal strandings (Frantiz, 1998).

e)Any operation of seismic surveys, vertical seismic surveys, CSEM and bathymetric surveys happening concurrently must be taken into consideration.

13.  RECURRING IMPACTS NOT CONSIDERED

The Draft Scoping Report has not taken into consideration the probability of recurring seismic surveys, vertical seismic surveys, further CSEM operations. The risks associated with compounded behavioural disturbance and how chronically-present sound could constitute a threat to populations by changing behavior and distribution regularly at critical times and in critical areas. 

a)     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

14.  LIGHT POLLUTION

Operations at oil fields introduce considerable amounts of artificial light (e.g., electric lighting, gas flares) that can potentially affect ecological processes in the upper ocean, such as diel vertical migration of plankton. Artificial night-light also attracts numerous species, including squid, large predatory fishes, and birds. Please evaluate for mitigation the effect of lights and the physical presence of ships on the movement of sensitive species.

15.  INVASIVE SPECIES

Ships, drilling equipment and rigs are used and relocated all around the world. Negative impacts on native biodiversity ,including risk to fisheries, from invasive species colonising drilling infrastructure should be mitigated. 

16.  MARINE PROTECTED AREAS BUFFER ZONES

The proximity of these potential wells to our environmentally significant areas Secret Reef, and the Kingklip Corals and fish , significantly commercial fish such as hake, spawning areas 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 Scoping Report should propose buffer zones adjacent to Marine Protected Areas and Critical Biodiversity Areas in order to protect marine biota inside the designated areas to mitigate mining impacts in these areas.

17.  TIMING OF IMPACT 

The timing of this exploratory drilling is critical for least possible impact on seasonal breeding, feeding, and migrations. Best practice is to mitigate negative impacts of oil exploration on endangered marine life 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 Humpback whale, Southern Right whale, sardine and critically endangered Leatherback and endangered Loggerhead turtle migration routes.

18.  WELL ABANDONMENT

More information is required with regards to well abandonment and its mitigation. How will TEPSA ensure monitoring will be carried out after production has ceased and throughout de-commissioning?

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 Draft Scoping Report 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.

This Draft Scoping Report has 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] TEPSA Draft Scoping  Report, paragraph 5.4, p. 40 

[ii] Nara, H., Tanimoto, H., Tohjima, Y. et al. (2014). Emissions of methane from offshore oil and gas platforms in Southeast Asia. Sci Rep 4, 6503 https://doi.org/10.1038/srep06503

[iii] Elvidge, C. D. et al. (2009). A fifteen year record of global natural gas flaring derived from

satellite data. Energies 2, 595–622, doi:10.3390/en20300595 

[iv] Howarth, R. W., Santoro, R. & Ingraffea, A. (2011).Methane and the greenhouse-gas

footprint of natural gas from shale formations. Clim. Change106, 679–690 

[v] 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.

[vi] 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.

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