Oceans Not Oil Comments On Karpowership Draft EIAs for Saldanha Bay (Western Cape), Port Of Ngqura (Eastern Cape) And Richards Bay (Kwazulu Natal)

This letter serves to lodge an objection to the proposed Gas to Power Powership Projects at the Ports of Richards Bay, Ngqura and Saldanha for the reasons listed below. It also serves to highlight numerous contentious issues with this EIA process. Our primary concern is that there is clear systemic injustice and fundamental flaws in the DEIAR process for this application, and as such Triplo Sustainable Solutions have failed to comply with the DEIAR requirements as set out in NEMA and the DEIAR Regulations and this is evident for the following reasons:

• LACK OF BEST PRACTICE 
  To date, no independent Strategic Environmental Assessment (SEA) has been conducted for marine oil and gas development. Negative impacts of this energy sector, namely oil spills, fossil gas leaks and pollution, to biodiversity are well documented and have massive health, wildlife, economic and societal consequences. Without an independent SEA conducted for this entire sector, project level environmental assessment remains uncomplemented by considerations fully adapted to policies, plans and programmes that minimize potential ecosystem harm measured against environmental baselines, or by having established indices for evaluating economic and social considerations, whilst taking into consideration the regional ocean systems. 
  
• INADEQUATE COST BENEFIT ANALYSIS
  A comprehensive cost benefit analysis has not been undertaken for the Proposed Gas to Power Powership Project. We say this because:

1. A true-cost accounting of these projects should have been supplied, including ecosystem valuation, social and economic costs and benefits or advantages.
2. The socio economic consequences of loss of tax revenue by tax breaks afforded the projects by the special economic zone (SEZ) tax incentive should have been detailed and projected over the 20 year life-span of these ‘projects’.
3. The socio economic consequences of the exemption from the 40% local content stipulation should have been detailed and projected over the 20 year life-span of these ‘projects’.
4. The socio economic consequences of sustaining foreign-sourced energy dependence should have been detailed and projected over the 20 year life-span of these ‘projects’.
5. The consequences of accidents, explosions or leaks on industries, individuals and the environment may be significant yet the aspect of compensation to these sectors has not been dealt with at all.
6. A projected worst case-scenario on LNG costs should have been calculated, since this is paid at the expense of the public purse. An annual renegotiation of the LNG pricing clause is recommended for these projects.
7. An ‘apples-for-apples’ cents/kWh projected pricing comparison between the gas-to-power powerships and renewables for the duration should have been supplied to allow for more appropriate cost decisions now and going forward. Gas-to-power powerships are neither a least cost option at R10.9 billion per year for taxpayers and electricity consumers, nor for their hidden costs and externalities.
8. A projected financial cost impact should have been calculated for 70% ‘baseload supply’ compared to ‘peaking’ / low capacity sector supply to allow for more appropriate cost decisions now and going forward.
9. The socio economic consequences and actual costs of contributing to the impacts of climate change on overall economic growth should have been assessed. The CMCC Foundation and RFF-CMCC European Institute on Economics and the Environment (EIEE) and Athens University of Economics and Business have projected a cost of up to 20% of GDP in their investigation into how climate change could impact the GDP of South Africa^[1]. Climate debt and the costs of not transitioning earlier than 20 years have not been considered and should have been factored into these ’projects’ considering that “over the expected operating lifespan of the Gas-to-power powerships of 20 years (74 460 operational hours), at constant 100% capacity, cumulative generation emissions are 19.56 million tons CO2e.”
10. LNG production, storage and transportation processes consume a considerable amount of energy. The energy return on energy invested calculation is an omission in this EIA process and should have been supplied. 

• STAKEHOLDER ENGAGEMENT

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

1. A major deficiency has been that the Triplo Sustainable Solutions’ DEIAR regime was online. This format is, in its nature, fundamentally exclusionary, privileging those with an appropriate device, enough wifi and 207 MB of data to load the webinar application. 
2. Complex technical discussion was in English, as is all literature, and failed to consider ethnodiversity. 
   It is particularly important that all stakeholders are provided with complete relevant information to allow for informed and impartial decision-making. Many of the Interested and Affected Parties (I&AP) do not speak English with the proficiency required to fully understand the literature to grasp the implications of these projects and how to address these. Meaningful public participation must account for the language barriers of South Africa’s multilingual society and provide clear, comprehensive and accessible information
3. Key biodiversity authorities, institutes, researchers and conservation groups were left out of the public participation plan. Critical interested and affected parties involved in disaster management planning and response were also not included. Any accidental release of HFO or gas, or system failure could have devastating impacts on people, livelihoods and the environment. 
4. There has been a stark lack of information on issues such as pricing, accumulative effects and ‘no-go’ options.
   

As such Triplo Sustainable Solutions’ stakeholder engagement does not comply with the provisions of NEMA, the Constitution and other legislation and regulations relating to the EIA process as well as the public participation process referred to in the abovementioned legislation. 

• RIGHTS OF FUTURE GENERATIONS/ NEED AND DESIRABILITY OF THE PROJECT

1. 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 methane slips and leakage/end outputs. This DEIAR has not provided a sufficient evidentiary base to answer key questions around fugitive methane emissions. Over 60% of methane emissions are fugitive, the rest are from vented or combusted emissions^[2]. Studies have shown that fugitive methane emissions from fossil gas operations, production facilities that include storage, and ancillary infrastructure are much higher than previously supposed. Liquefaction, tanker transport, and regasification increase total life-cycle emissions by as much as 21 percent. The EIA must provide the public with a report on cradle-to-grave emissions over the span of the development activity. 
2. Non-fossil fuel options have not been properly and objectively considered. Triplo Sustainable Solutions need to support the their claim that “Supplementary baseload will have to be sought elsewhere, possibly from sources with higher GHG emissions than LNG”^[3] as alternative options. Life-cycle GHG emissions for solar power are less than 7 percent of LNG emissions; emissions for wind power are even lower, less than 2 percent of LNG emissions. Also the GHG no-benefit threshold occurs at between 1.9 to 3.2% methane leakage when fossil gas is used in the place of coal^[4].
3. Gas-to-power powerships operating at 72% capacity for 16.5 hours a day for 20 years will impact South Africa’s ability to deliver on a just transition, a just recovery, and embedded energy timeously, not least because capital will be locked into this fossil gas development.
4. Gas infrastructural development further locks in South Africa’s carbon budget, producing more GHG emissions by 2040 than would be consistent with limiting warming to 1.5°C. South Africa is already warming at twice the global average^[5] and there is an urgent need to reduce methane emissions to avoid putting the rights and lives of future generations at risk.
5. Harmful human health impacts associated with gas infrastructure include foetal abnormalities, respiratory illnesses, endocrine disruption and cancers. Petrogenic carbon from methane releases can negatively affect phytoplankton biomass and community composition especially when dispersants are used^[6]. 

• SOUND, AIR, TEMPERATURE, AND BIOLOGICAL POLLUTION

1. SOUND
   1. Noise impact assessments show impermissible levels of noise in the vicinity of the ships, well above ambient levels . The future development of these special economic zones has not been taken into account and the gas-to-power powership noise levels have the potential to inhibit development within these zone. 
   1. The cumulative impacts of the ensonification of the special economic zones have not been considered.
   1. The cumulative impacts of the ensonification and whole-body vibration (WBV) in fish habitats has not been considered. It was noted in 2012, by Koper and Plön, that South Africa lags behind in its knowledge on the impacts of anthropogenic sounds on its marine life, and although the development of industry is often seen as a positive initiative to create job opportunities, the long-term effects of these developments on the marine environment are potentially being overlooked^[7]. Some threshold studies, which have only reported on only sound-pressure, may be of limited use for certain commercially valuable species, as not all species equally detect the pressure component of sound. Particle motion sensitivity, or to a combination of both particle motion and acoustic pressure, should be considered in noise impacts studies on fish and invertebrates, particularly those species lacking a gas-filled bladder (i.e. all elasmobranchs and marine invertebrates).
      1. Richards Bay harbour is a particularly important nursery habitat for juvenile fish^[8]. Larvae and juveniles may be more susceptible to harm from this ensonification in comparison to the adults of their species, potentially jeopardizing the sustainability of various populations (Banner 1973).
   1. Another overlooked aspect of noise impacts from the ships is the ‘disruption of rest periods’, which are important to moving marine animals. The notion that animals can/will simply swim away from the widespread, disturbing noise is contentious since the valuable energy and attention used by animals for simply swimming away is at a high cost to the animal. Protocols to limit the disruption of rest are required
   1. The DEIAR has not considered the risks associated with compounded behavioural disturbance and how ever-present sound could constitute a threat to populations by changing behaviour and distribution regularly at critical times and in critical areas.
2. AIR
   Assurances have been made that the energy created by the gas-to-power powerships will produced from LNG not HFO, however the ship itself is run on HFO. HFO was included in the EIA as a comparison to LNG, which leads us to ask:
   1. If supply of LNG is compromised what other fuel will be sourced? 
   2. If LNG becomes unprofitable what other fuel source will be used?
   3. These alternate fuels needs assessing in the EIA to ensure these projects operate optimally and sustainably for its lifespan.
   4. What grade of HFO will be utilised?
   5. Exposure to Heavy Fuel Oil is toxic to humans and wildlife, and highly polluting to the environment on several dimensions. Heavy Fuel Oil is :
      1. highly concentrated in sulphur (35,000 parts per million) and vanadium. Sulphur dioxide emissions (SO2), are highly acidic when mixed with water and a major contributor toward acid rain and respiratory diseases. Vanadium exposure is suspected of causing genetic defects, damage to organs through prolonged and repeated exposure and is toxic to aquatic life.
      2. produces poisonous nitrous oxide and carbon emissions. The heavy particulate matter from Nitrogen Oxide can cause serious lung diseases, especially among young children.
      3. has been linked to an increased risk of heart and lung disease as well as premature death
      4. doesn’t readily disperse or breakdown in the marine environment
      5. has a tendency to stick to surfaces or sink and emulsify in sea water
      6. contribute to anthropogenic (human-induced) climate change 
      7. becomes more toxic when exposed to Ultra-Violet (UV) light and can be absorbed by organisms, increasing their mortality. 
      8. the compounds in the burn residue from combustion have a higher potential for bioaccumulation and also may include mutagens and carcinogens so the formation of smoke and soot is a matter of both environmental and health concern, in particular regarding inhalable particles and particle deposits.
      9. The risks of transport of HFOs are significant^[9].

These health impacts and pollution outcomes potentially have direct effects on exposed public, in close proximity to the gas-to-power powerships for any length of time, or resident biota. These impacts need to be more comprehensively assessed in the EIA.

• TEMPERATURE CHANGES

1. That the heated water effluent from the gas-to-power powerships raises the ambient temperature of the water around it by 3-5 degrees in a 100m radius indicates this temperature is significant. This is especially concerning considering that studies have shown that warming ocean temperatures have been associated with decreased productivity, diversity, and resilience of nearshore marine ecosystems over the past few decades^[10] and are likely to cause uncoupling of predator prey dynamics and populations as species’ ranges shift in response to preferred thermal environments. The actual temperature of the discharged water, when the ships are running at full capacity, must be made public seeing that it could compound the pressures and stresses placed on biota, small-scale fisheries and the achievement of Sustainable Development Goal 14.

• BIOLOGICAL POLLUTION 
  1. Gas-to-power powership defouling processes must be assessed seeing as the intake of seawater into any pipe or plant system will lead to biofouling – accumulation of microorganisms, plants, algae, or animals – from sea water on the internal seawater piping systems.
  2. The gas-to-power powerships and infrastructure may serve as vectors for the introduction of non-native species through inadvertent transport of organisms. Lists of probable/anticipated non-native species should be supplied to aid mitigation measures.

This DEIAR requires more rigorous expert judgment in evaluating wholistic risks to human health, marine life, and climate change for the benefit of all, and should evaluate the option of not proceeding with further activity.

We trust the above matters will be taken into consideration. 

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^[1] Shayegh, S., Manoussi, V., & Dasgupta, S. (2020). Climate change and development in South Africa: the impact of rising temperatures on economic productivity and labour availability. Climate and Development, 1-11.

^[2] Kirchgessner, D.A., Lott, R.A., Cowgill, R.M., Harrison, M.R., Shires, T.M. (1997) Estimate of methane emissions from the US natural gas industry. Chemosphere 35: 1365–1390. Available at <https:www3.epa.gov/ttn/chief/old/efdocs/methane_dec2000.pdf>

^[3] Table 8-5 Impact of the No-Go Alternative  p. 179

^[4] Scholes, R., Lochner, P., Schreiner, G., Snyman-Van der Walt, L. & de Jager, M.(Eds.). (2016). Shale Gas Development in the Central Karoo: A Scientific Assessment of the Opportunities and Risks. CSIR/IU/021MH/EXP/2016/003/A, ISBN 978-0-7988-5631-7

^[5] Engelbrecht, F. A., Adegoke, J., Bopape, M-J, Naidoo, M., Garland, R., Thatcher, M., McGregor, J., Katzfey, J., Werner, M., Ichoku, C., & Gatebe C. (2015). Projections of rapidly rising surface temperatures over Africa under low mitigation, Environmental Research Letters. 10 085004.

^[6] Gracia, A., Murawski, S. A., & Vázquez-Bader, A. R. (2020). Impacts of Deep Oil Spills on Fish and Fisheries. In Deep Oil Spills (pp. 414-430). Springer, Cham.

^[7] Koper, R. P., & Plön, S. (2012). The potential impacts of anthropogenic noise on marine animals and recommendations for research in South Africa. Endangered Wildlife Trust.

^[8] Weerts, Steven & Cyrus, Digby. (2002). Occurrence of young and small-sized fishes in different habitats within a subtropical South African estuary and adjacent harbour. Marine and Freshwater Research. 53. 447-456. 10.1071/MF01155.

^[9] Fritt-Rasmussen, J., Wegeberg, S., Gustavson, K., Sørheim, K. R., Daling, P. S., Jørgensen, K., … & Holst-Andersen, J. P. (2018). Heavy Fuel Oil (HFO): A review of fate and behaviour of HFO spills in cold seawater, including biodegradation, environmental effects and oil spill response.

^[10] Pinsky, M. L., Eikeset, A. M., McCauley, D. J., Payne, J. L., & Sunday, J. M. (2019). Greater vulnerability to warming of marine versus terrestrial ectotherms. Nature, 569(7754), 108-111.