Oceans Not Oil Objects – CGG Services Application

Below you’ll find our written objection to the CGG Services seismic survey application.

In the video you’ll witness the telling moment today (29 Nov 2021) when Oceans Not Oil delivered these documents along with the 18529 written objections made by signatories and the list of 314361 signatures (at time of delivery) to the We Object to Shell and CGG Seismic Surveys on RSA Coast petition  https://www.change.org/p/shearwater-geoservices-shearwatergeo-and-shell-stop-blasting-the-wild-coast-our-voices-can-make-a-difference-and-put-an-end-to-shell-blasting-in-the-wild-coast ) to the Kloof branch of environmental assessors SLR Consulting.

CGG Services – Speculative 3D Seismic Survey off the Southeast Coast of South Africa SLR Project No: 720.03122.00001 pertains

This letter serves to lodge an objection to the proposed speculative three-dimensional (3D) seismic survey in the Algoa, Gamtoos and Outeniqua Basins off the southeast coast, South Africa, by CGG Services SAS (PASA Reference: 12/1/037).

It is acknowledged that SLR Consulting is no more than a go-between between PASA, the Department of Mineral Resources and the rights holders of the above areas, and the results of these documents are merely summarised into a table, responses are given to justify how SLR has done their homework, a mere tick box exercise as per NEMA requirements. However, South African citizens believe that there is more at stake than just a few threatened species, but rather evidence of a clear divergence of goals between the DMRE and Department of Forestry Fisheries and the Environment (DFFE) in terms of climate goals and obligations.

SLR adds that the information gaps in the EMP include:

• details of the benthic macrofaunal communities beyond the shelf break;
• details on demersal fish communities beyond the shelf break; 
• information specific to the marine communities of submarine canyons (Sundays, Addo and
  Cannon Rocks Canyons); and
• current information on the distribution, population sizes and trends of most cetacean species occurring in South African waters and the project area in particular.

Throughout this EMP, there is a theme of acknowledgement that there are impacts and that information is scarce but when the science is clear, it is disputed and downplayed for the benefit of the client. There are many opinion-based conclusions and there is complete disregard for the precautionary principle.

As it stands, the ‘international best practice guidelines’ do not comply with the spirit in which the NEMA ToPS regulations were drafted. There is disregard for these species because there is a lack of knowledge. In every other case, the precautionary principle should have been applied but the DMR are notorious for ignoring this principle in their endeavours. 

The notion that NGOs and NPO’s are required to prove that these seismic surveys would cause “irreparable harm” is not reasonable. The oil and gas companies, the DMR, PASA and DFFE should be undertaking research programmes to prove that they are doing no harm. These are the entities which are funded privately and/or with tax-payer funds given they are wanting to exploit resources which belong the people of SA. However, given the increasing knowledge and research which is being undertaken internationally on seismic surveys, it is doubted that ‘irreparable harm’ would ever be proven, hence the lack of interest to develop research programme in the interest of the environment. Operation Phakisa is all about ‘hurrying up’, but there has been no hurry in exploring the impacts of the oil and gas sector.

The objection is based on the following, inter alia:

NEEDS AND DESIRABILITY

It is disingenuous to suggest that the proposed exploration won’t impact South Africa’s reliance on hydrocarbons and whether consumers use more or less oil or gas – is not the purpose to find more useable reserves? As a stakeholder, one has to assume that there is intension to extract. In May 2021, the International Energy Agency (IEA) published a high-profile report ^[i] that detailed the pathway to achieving net-zero carbon emissions by 2050, and in the report the agency concluded that expanding fossil fuel exploration and use must end:

“No new natural gas fields are needed in the [Net Zero Emissions scenario] beyond those already under development,” 

The International Energy Agency (IEA) has concluded that if planetary systems are to remain within the two degree limit, no more than one-third of proven reserves of fossil fuels can be consumed prior to 2050.^[ii]  
It is trite that investigating alternative sources of renewable energy could replace the exploration and utilisation of fossil fuels, replacing South Africa’s aging and inadequate electricity generation capacity whilst spurring economic growth (Valli Moosa, deputy chairman of the Presidential Climate Change Coordinating Commission), in the urgent matter cutting 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. 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 possible 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.

SLR’s statement acknowledges that there is neither desire nor intention to change from exploiting fossil fuels. The argument that one project cannot change the face of use of certain types of energy in South Africa is grossly naïve. May we draw your attention to the current protests to the Transkei and Algoa Exploration Right (dubbed the Shell / Wild Coast protests) where over 311 000 signatures have been submitted on the ‘We Object to Shell and CGG Seismic Surveys on RSA Coast!’ Change.org petition (see attached annexure) and court papers have been filed, giving a clear indication that the public are incensed by the lack of respect and integrity the DMR have shown not only for the global climate future, but also for the marine environment and intangible heritage.

LEGISLATIVE REQUIREMENTS

1. At the time the Reconnaissance Permit Application was submitted to PASA legislative and environmental requirements for offshore seismic surveys had changed radically due to their repeal in June 2013, with the onset of Operation Phakisa fostering rapid 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.

• 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”^[iii]. This EMP needs a higher survey endeavour reflecting South Africa’s commitment to the aforesaid convention.

TIMING OF IMPACT 

The recommended timing of the survey between January to end of May 2022 is lodged with the caveat of being ultimately dependent on a permit award date, availability of the survey vessel and the scheduling of 3D surveys to either coincide or not. History tells us that, permits to undertake these surveys simply cannot be issued within a month without proper consideration and consultation with stakeholders without blatant disregard to the process.  It is of great concern that the survey will be extended into the peak whale migration (May /June / July). Previous extension permits (Schlumberger, 2016) have been extended into these periods with no concern from DMRE or PASA.

The current application (Transkei and Algoa Exploration Right) due to start on 1 December 2021, will potentially be in full swing when this survey begins. The cumulative impact and effects on the environment have been grossly understated. If SLR were to be considered responsible and truly take cognizance of the dual impacts, this EMP would have had to be written in a very different manner, taking into account dual impacts and increased sound in the water. The EMP as it stands is irrelevant.

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. 

Furthermore, turtle hatchlings being present in the area is acknowledged but the survey date is still considered to be within a ‘window period’ in which there is minimal impact. Turtle hatchlings cannot ‘leave the area’ during soft-starts. There is currently no mitigation for leatherback and loggerhead turtle hatchlings, only the adults, which are not in the area during this period. 

ISSUES WITH USE OF ‘GENERIC’ EMP GUIDELINES

1. The EMPr understates the compounding effects of multiple abiotic and biotic stressors associated with multiple 3D surveys being undertaken concurrently. A multiple survey interaction must be considered to clarify whether the interaction is synergistic, additive, or antagonistic. As mentioned above, there is no mention of the Transkei and Algoa Exploration Right due to start on 1 December 2021, Therefore, the impact and effects of these environments have been grossly understated. 
   
2. Due to the frequency and enormous extent of the multi-client surveys and exploration planned for 2020-2022 the assumption that larger/more mobile and/or migratory animals will avoid and move away from seismic surveys needs serious revision. Cumulative 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.
   
3. The potential effects of the 3D surveys have largely been brushed aside. It is noted, however, that previous EMP’s drafted by SLR on seismic surveys were stated as “insignificant” or “low”. This has now been elevated to “low” and “Medium” within this EMP, even though SLR continues to dispute scientific information. This slight improvement of opinion-rated effects on marine fauna is acknowledged but at what scale do mitigation processes and recommendations to stay out of certain areas begin to change? The rating has been elevated but there are few changes in actual mitigation measures and recommendations.
   
4. Furthermore, there is still 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 12 fishing sectors and our food security. This demands a critical and more thorough review of any suspected risk.
   1. 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.
      
   1. Furthermore, the EMP states that “Due to the extensive distribution and feeding ranges of pelagic seabirds, the impact for pelagic seabirds would thus be of LOW intensity within the survey area (REGIONAL) over the duration of the survey period (SHORT TERM – 5 months). For African Penguins and Cape Gannets, the impact for would thus be of HIGH intensity. As there is a high likelihood of encountering feeding birds in the inshore portions of the Reconnaissance Permit Area, the intensity is considered MEDIUM. The duration of the impact on the population would be limited to the SHORT-TERM (5 months) and be restricted to the survey area (REGIONAL). The behavioural avoidance of feeding areas by diving seabirds is thus considered to be of magnitude and for coastal diving seabirds to be of magnitude VERY LOW “. This paragraph acknowledges that the pelagic seabirds will be impacted but their endangered status, dramatic declines in populations, pressures from avian flu outbreaks, other anthropogenic pressures and lack of prey items, there is little cognizance of the consequences to the local population of an endemic species. 
      
5. 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. 
   1. Cummings et. al. (2004) make it clear that even though animals take refuge near the surface from “dangerous or annoying sound levels below” in a sound interference shadow, there is no “zone of silence.” These areas have not been taken into account in the noise modelling study

• 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 “low” 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.
  
  • The noise study models sound but what continues to be misunderstood and misrepresented is the constant and consistent drone of noise, even when it is considered low and does not cause PTS or TTS, the very presence of increased sound in the water column has impacts on the fauna.  
    
  • In the noise modelling study, there is a reference to the U.S. National Oceanic and Atmospheric Administration (NOAA) panel of experts who developed noise exposure criteria for fishes and sea turtles. This panel was convened in 2004. Given that research on the impacts of seismic surveys has grown substantially in the past 15 years, using standards based on old data, primarily based in very different ecosystems and offshore conditions is disingenuous.
    
• 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^[iv]. This damage was seen at exposure levels that might occur several kilometers away from the airguns. Also pertinent are increased stress signals^{[v],[vi],[vii],[viii]}; disruption in schooling and migration^[ix]; disruption of homing or orientation^[x]; decreased feeding efficiency[xi]; and reduced catch rates of 40-80% in areas more than 30 km from seismic surveys^{[xii],[xiii],[xiv].}

MARINE PROTECTED AREAS

The avoidance of the MPA with a buffer zone of 1km is ludicrous given sound travels 100’s of kilometres under water. The noise study estimates that the zones of PTS impact are predicted to range up to 800 m and the zones of TTS impact are predicted to be up to 12.0 km from survey lines. The manner in which the MPA will be avoided (i.e. no firing of airguns inside MPA including a 1km buffer zone) is nothing more than a token. Based on the SLR noise modelling study, a buffer area of at least 15km should be placed around the Port Elizabeth Corals MPA, which is a spawning area, harbours rare cold-water corals and lies within Critical Biodiversity Areas (CBAs) and Ecological Support Areas (ESAs).  

In South Africa, more conservative approaches to mitigation measures should be taken when in the vicinity of MPA’s and when threatened (vulnerable, endangered and critically endangered) species are being intercepted. The mitigation zone should be at least 1220m, the pre-startup watch period should be expanded to 120 minutes as a safeguard against any deep-diving whales’ being in the safety zone. 

COELACANTH

The south and eastern Cape coasts are riddled with canyons which are important and unique features, and are suitable for coelacanths. Given the first coelacanth sighting in East London, the coelacanths present at Sodwana Bay and offshore Pennington, it is presumed they move along this coastline between canyons. Research indicates that the Coelacanth population may be significantly smaller than anticipated, raising concerns regarding the potential sensitivity of this species to disturbance and disturbance of its habitat (Dr Kerry Sink, pers. comm). Furthermore, canyon walls may be susceptible to collapse from the energy waves generated during seismic surveys. In view of these concerns, all canyons should be afforded a minimum 10 km buffer, so as to ensure that the exploration has no significant negative impacts upon coelacanths or their habitat.       

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. 

The area of interest overlaps with the fishing grounds of seven fishing sectors, namely demersal trawl,

midwater trawl, demersal longline, large pelagic longline, South Coast rock lobster, squid jig and small-scale fishing for squid (marginally).

1. 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 15 428 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.

• 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^[xv]. 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^[xvi].

• Potentially, from the annual South Africa squid catch data, there is a correlation between seismic surveys and drop in squid jig catches^[xvii]. 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^[xviii]. This survey therefor poses significant risk to this fishery.

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.

INCORPORATING NEW MITIGATION TECHNOLOGIES INTO GUIDELINES FOR THIS APPLICATION

1. 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).
   
2. If SLR is working towards implementing worldwide best practice mitigation procedures Marine 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  – Tsitsikamma MPA, Sardinia MPA, Robberg MPA, Addo Elephant MPA, Algoa Bay Project, Port Elizabeth Corals MPA, Kingklip Koppies ecosystem, Agulhas Coarse Sediment Shelf Edge ecosystem and the Agulhas Sandy Outer Shelf ecosystem – 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 minimal biological baseline data.

It is recommended that the survey area be reduced to exclude the entire area inshore of the MPA for the full length of the exploitation area / area of interest. This will assist in protecting the existing MPA and the fishing grounds. 

Once again we would like to reiterate that this EMPR is grossly negligent given there is potential for two seismic surveys to be undertaken concurrently. 
 

For all the above reasons, we look forward to your most urgent response and trust the above matters will be taken into consideration. 

Yours sincerely,
Oceans Not Oil
www.oceansnotoil.org
info@oceansnotoil.org

Affiliates to the Oceans Not Oil campaign are:
Organisations

• African Conservation Trust
• AfriOceans Conservation Alliance
• Animal Survival International
• Centre for Environmental Rights
• Conservation Guardians
• Coastwatch
• Coastal Links (KwaZulu Natal)
• Conservancies KZN
• Earth Life Africa (Durban)
• Eastern Cape Environmental Network
• Embabhaceni Development and Nature Solutions
• Fisherfolk Formations
• FrackFree SA Youth
• Green Thumb Society
• groundWork
• KwaZulu Natal Marine Stranding Network
• Legal Resources Centre
• Mayine Azanian Movement
• Masifundise Development Trust
• Sardine Run Association
• Sentinel Ocean Alliance
• South African Youth Climate Change Coalition
• South African Squid Management Industrial Association
• South Durban Community Environmental Alliance
• Sustaining The Wild Coast
• The Bluff Work Experience and Volunteer Program
• Umkomaas Fishing Forum
• Vaal Environmental Justice Alliance
• Vanishing Present Productions
• Wildlands

Commercial

• Shark Warrior Adventures
• Ufudu Flyfishing Safaris

International

• Parley For The Oceans

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REFERENCES

^[i] IEA (2021), Net Zero by 2050, IEA, Paris. Available at <https://www.iea.org/reports/net-zero-by-2050&gt;

^[ii] Energy Outlook, supra note 39, at 241.

^[iii]  International Whaling Commission, Environmental concerns: Anthropogenic Sound, viewed 5 Sept 2018, <https://iwc.int/anthropogenic-sound >

^[iv]  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. 

^[v]  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

^[vi]  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 

^[vii]  Wysocki LE, Ladich F, Dittami J (2006). Noise, stress, and cortisol secretion in teleost fishes. Biological Conservation 128, 501–8. 

^[viii]  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.

^[ix]  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 

^[x]  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.

^[xi]  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. 

^[xii]  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.

^[xiii]  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.

^[xiv]  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

^[xv]  Shinovene, I. (2013) Govt fears tuna depletion as oil and gas exploration chase fish away [online]. Nambia: The Nambian, 25 November 2013). Available from: 

http://www.namibian.com.na/indexx.php?archiveid=116959&pagetype=archivestorydetail&page =1 

^[xv] 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

^[xv] 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>

^[xv] 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>

CITATIONS

Cummings, J. and Brandon, N., 2004. Sonic impact: a precautionary assessment of noise pollution from ocean seismic surveys. Accessed online April, 24, p.2009.

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. 

McCauley, R. D., et al. (2017). “Widely used marine seismic survey air gun operations negatively impact zooplankton.” Nature Ecology & Evolution 1(0195): 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.

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 Mammals 39: 356–377.

Richardson, W.J., Greene, Jr., C.R., Malme, C.I., Thomson, D.H. 1995. Marine Mammals and Noise. Academic Press, San Diego.

Pichegru, L., et al. 2017. “Avoidance of seismic survey activities by penguins.” Scientific Reports 7(16305): 8. 

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 

Vanek, M.  1 June, 2021. Moving to renewable energy will boost economic growth, Valli Moosa says. Business Day. Available at <https://www.businesslive.co.za/bd/national/2021-06-01-moving-to-renewable-energy-will-boost-economic-growth-valli-moosa-says/&gt;