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Letter to the Ministers

Oceans Not Oil wrote off to the Minister of Mineral Resources and Energy, and the Director General, as well as the Minister of Forestry and Fisheries and Environmental Affairs and the Director General ( 1 Dec 2021)

Here is our letter;

Dear Sirs/ Mesdames and other interested persons referred to above,

I write on behalf of Oceans Not Oil (“ONO”) which is an organisation consisting of thirty-three affiliated members.  A list of the affiliates is attached to this letter as annexure “A”.

I furthermore write this letter on behalf of the more than 372,800 persons who have appended their signatures to a petition objecting to the proposed seismic testing in the Transkei Exploration Area calling on Minister Creecy and Minister Mantashe to withdraw the approval of this proposed activity.

On 29 November 2021, I, along with numerous other interested citizens of this country, attended at the offices of SLR, the agents appointed by SHELL to undertake the so-called Environmental Authorisation related to this activity, in order to notify that company of the existence of the aforesaid list of signatories as well as a list of all of the approximately 18 500 written objections to the proposed seismic testing.  I might mention that the aforesaid offices were shut and the employees of SLR were not present at their offices at the time that we attended, despite the fact that they were well aware of our intention to hand over the documents containing the list of objections and the document containing all of the signatures.

Be that as it may, I have no doubt that you are well aware of the application which has been set down for hearing, on an urgent basis, in the Grahamstown High Court of the Eastern Cape Division, and due to be argued at 2 pm today, 1 December 2021.  You are, no doubt, furthermore aware that the relief that is sought in that application is for, inter alia, an order interdicting BG INTERNATIONAL LIMITED, SHELL EXPLORATION AND PRODUCT SA and IMPACT AFRICA from undertaking seismic survey operations. I am advised that the departments referred to above are likewise cited in the application.   

We echo and repeat the request that the proposed seismic activity be halted forthwith. 

We furthermore demand that the decision to award the Reconnaissance Permit and exploration right be reconsidered and set aside, failing which an appeal, alternatively, a review of the decision by the Department of Minerals and Energy to grant the exploration right in 2013 and the decision of the Department of Environmental affairs to sanction the purported environmental authorisation subsequent thereto, shall be instituted without further notice to you.

It is our contention that the award of the exploration right to IMPACT AFRICA in 2013 was ultra vires and in breach of, inter alia, the provisions of the Constitution which provide for the right to an environment that is not harmful to the health and well-being of all South Africans and to have the environment protected for the benefit of present and future generations.  

We dispute your contention that such authorisation was properly granted and refer to the further provisions of the Constitution which provide that everyone has the right to administrative action that is lawful, reasonable and procedurally fair.

Further reasons for our contention that the exploration right should be withdrawn, alternatively, set aside are the following:

  1. The Just Energy Transition Partnership pledge following the recent Cop26 (Conference of Parties) is expected to prevent up to 1-1.5 gigatons of emissions over the next 20 years and  to encourage South Africa to accelerate its transition to a low emission, climate resilient economy. The Intergovernmental Panel on Climate Change has shown the unabated use of natural gas will have to be reduced by over 70 % of current use in 2021.  The reconnaissance for offshore gas or oil, with the end goal being production of the same, is incompatible with achieving the climate-neutrality objective by 2050 and the acceleration of the decarbonisation of South Africa‘s electricity production. 
  • The public and the Oceans Not Oil coalition was made aware of the survey only on 2 November 2021 with the notice published in the Daily Dispatch Newspaper on that day.  Oceans Not Oil and its affiliates had no knowledge that the Reconnaissance Permit was granted in 2014.  The renewal was likewise not communicated in accordance with the principles of fair administrative justice, either to the existing I&APs or to the general public.   The material changes in interests in the Exploration Right viz to ExxonMobil Exploration and Production South Africa Limited and to Shell Exploration and Production South Africa were likewise not communicate to either ONO, the I&APs or the general public.
  • INSUFFICIENT MITIGATORY MEASURES
  • Strong critique has been levelled at the JNCC seismic survey guidelines specified in the EMPR [see Wright and Cosentino (2015), Weir and Dolman (2017)]. Wright et al (2013) warn that these guidelines have “little scientific basis” and “questionable efficiency”.[i] 
  •  There is no baseline research on the effects seismic surveys will have on this particular marine environment (Morgan Bay to Port St John’s). 
  • Threatened loggerhead and leatherback turtle hatchlings will be swimming in the same current as Shell Exploration and Production South Africa intends operating from January until early April. Baby turtles are entirely at the mercy of ocean currents and cannot evade sounds at levels which may cause injury, nor can they avoid these huge airgun arrays travelling at 4 – 6 knots.  There are no mandatory mitigation measures for turtles are included by JNCC (2010). Additional measures of widening a visual area to 500m may still lead to physical injury and behavioural alterations in turtles (Nelms et al., 2016).  Equally important are the migration corridors used by turtles as offshore habitats and foraging grounds (Godley et al., 2010). Nelms et al., (2016); Parente et al., (2006), Pendoley, (1997) and  Whittock et al., (2014) all suggest that implementing time–area closures should be the primary mitigation measure adopted by governments, seismic operators and environmental management organisations during the planning stages of seismic surveys to avoiding nesting seasons due to the potential disturbance to breeding females and emerging hatchlings[ii]
  • Recurring impacts have not been considered. CGG Services may also be operating along the coast in the same current simultaneously.  Parsons et al. (2009) warn that the JNCC “operational guidelines are concerned only with the reduction of immediate effects.  However, some of the more insidious, and potentially devastating, impacts arise through long-term, repeated, persistent or cumulative exposures.”[iii]
  • In 2018 a resolution was proposed at the 67th International Whaling Commission for the elimination of acoustic pollution that affects whales (all 13 species). 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 Shell Transkei Block Exploration Right (ER) 12/3/252 this application. The IWC classes anthropogenic sound “as either acute or chronic.  Acute noise such as seismic surveys or military sonar is high in intensity and short in duration.”[iv] As such, the authority which forms the basis of this appeal falls squarely within the objectives of the aforesaid resolution.
  • NEW SCIENCE AND DEVELOPMENTS NOT TAKEN INTO ACCOUNT
    • It is deeply disingenuous and dangerous to suggest that there have been no significant changes to the surrounding environment of the project between the submission of the final EMPR and the implementation of the proposed project. We believe the following changes should have substantially influenced findings and recommendations with respect to mitigation and management to the point of ceasing and desisting the survey, and undermine the credibility of the study or the required management actions included in this EMPR.
  • ESCALATING CLIMATE CHANGE & RECENT CLIMATE SCIENCE MITIGATORY MEASURES

Since 2013 oceans have continued to absorb excess heat (Masondo, 2020) and carbon dioxide in the atmosphere from anthropogenic emissions (Stocker et al., 2014). The Intergovernmental Panel on Climate Change (IPCC) Special Report on the Ocean and Cryosphere in a Changing Climate (2019) reveals that ocean warming, its consequential acidification (National Academy of Sciences Committee on the Science of Climate Change, 2001) and oxygen loss (Laffoley & Baxter, 2019) are already disrupting marine ecosystems, impacting ocean biodiversity (Laffoley & Baxter, 2019) upon which people depend (Pörtner et al., 2019; Kroeker, 2013).  Ocean warming creates sea level rise and the IPCC (Pörtner et al., 2019, p. 18) predicts more frequent extreme sea-level events, further ocean acidification and oxygen decline. Once rare, extreme events are likely to occur now once a year (Pörtner et al., 2019, p. 20). In 2019 two cyclones, within the same season, battered southern Africa, killing over a thousand people and leaving over two and a half million people in need of humanitarian assistance[v]. Scientific consensus in IPCC reports (Rogelj et al., 2018; Masson-Delmotte et al., 2019) warns that continued oil and gas production exacerbates all of these effects. 

South Africa has warmed at around twice the rate of global warming (Engelbrecht et al., 2015), experiencing more frequent drought[vi], extreme heat (Shongwe et al., 2009), coastal erosion and flooding (D’ Sa, 2019). It is expected that cyclone intensity and precipitation will increase (Fitchett, 2018), posing a disproportionately higher risk to the vulnerable and poor (Islam & Winkel, 2017) and thwarting poverty reduction and development efforts (Harrold et al., 2002) in South Africa, exacerbating deep inequality (World Bank Group, 2018) and poverty (Diffenbaugh & Burke, 2019). 

  • EMISSIONS 

In May 2021, the International Energy Agency (IEA) published a high-profile report [vii]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 IEA said. “Also not needed are many of the liquefied natural gas (LNG) liquefaction facilities currently under construction or at the planning stage.”

The agency went on to add that the volume of LNG traded needs to fall sharply going forward. The (IEA) 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.[viii] Therefore two-thirds of proven reserves of oil, coal, and natural gas, including existing reserves, must be left in the ground to stay within the global carbon budget.[ix] 

A Natural Resources Defence Council (NRDC) study (December, 2020)[x]found that the climate benefit of LNG compared to coal is only modest at best, and because of the leakage inherent in producing the gas and the energy required to cool it and ship it, it ultimately presents a significant threat to the climate.

Tollefson’s (2017) study shows that offshore seismic surveys kill plankton.[xi] Not only is planktonic life the basis of the marine food chain, meaning these seismic surveys threaten the food security for marine life in the survey zone, but also the Jónasdóttir et al (2015) study shows that planktonic crustaceans lock up carbon from phytoplankton, keeping it out of the atmosphere and play a significant part in cycling carbon around the planet[xii] therefore helping to control climate change.

In 2017, McCauley et al[xiii]., showed that marine seismic survey air gun operations can kill large swathes of plankton, up to 1.2km from the sound source. Furthermore, all larval krill, the primary food source of whales, were killed. Considering the Agulhas Current which can move at four meters per second, and the increase in biomass distribution in this area, it would therefore be prudent that up-to-date and evidence-based science be considered.

  • MPAs

Twenty new Marine Protected Areas (MPA) have been approved by Cabinet since this 2013 EMPR. Pertinent to the Shell Transkei Block Exploration Right (ER) 12/3/252 application was the promulgation of the Amathole, Amathole Offshore, Dwesa-Cebe, Hluleka and Pondoland MPAs. These were vital for the protection of threatened, endemic and sensitive ecosystems, their high habitat diversity and for linefish recovery.

Given that the EMPR, as approved in 2013, no longer reflects the “current environmental context” it is clear that a new environmental impact assessment is required and the public participation process needs to be re-visited with this new environmental context in mind.

Seismic sound travels for tens of thousands of kilometres the proposed seismic buffer zone of 10 km from the coast and 2 km around the MPAs may be ineffective considering the impactful source of sound (230 – 250 dB).

Stress in marine mammals related to anthropogenic noise exposure has been conclusively proven, and prolonged exposure to noise stressors is known to cause significant impacts on marine mammals[xiv]. The proximity of this survey to our environmentally significant areas poses a great risk to our marine commons and heritage, the economic importance of our fisheries, and the leisure and tourism industries dependent on functional, healthy oceans.

  • SMALL SCALE FISHERS 

Seismic surveys have been shown to scare fish away from their usual habitats and the destructive effects on eggs, larvae and fry by seismic surveys have been shown to impact fishing success.[xv](Engås et al., 1993). 
A study 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 activity from oil and gas in the Orange River Basin, driving tuna from their normal migratory routes[xvi]. McCauley, Fewtrell and Popper (2003)[xvii] found that the ears of fish exposed to an operating air-gun sustained extensive damage to their auditory hair cells (sensory epithelia). The damage was severe, with no hair cell regeneration 58 days after air-gun exposure. This damage was seen at exposure levels that might occur several kilometres away from the air-guns

In 2019 and 2020, Minister Barbara Creecy granted 15 year rights to 78 new small scale fishing cooperatives in the Eastern Cape. This followed the historic development of the small scale fisheries policy in 2012,  which aimed to provide ‘redress and recognition to the rights of Small Scale fisher communities in South Africa previously marginalized and discriminated against…’.  Co-operatives from Cold Stream, Kareedouw, Humansdorp and Gqeberha, Port Alfred, Hamburg, Benton, Kiwane and Kei Mouth, Centane, Ntubeni and Port St Johns met in the week after the notification to confirm that they were not consulted (https://oceansnotoil.org/2021/11/19/where-are-we-supposed-to-fish/). They expressed grave concerns about the extent of the survey on the breeding, spawning and migratory routes of the species they have been granted rights to harvest. These small scale co-operatives stand aggrieved by, and may be made materially and adversely affected by, the administrative approval pertinent to the Shell Transkei Block Exploration Right (ER) 12/3/252 application made in terms of the MPRDA.

Insufficient attention has been given to investigating and considering the socio-economic impacts of the reconnaissance process. The public participation process appears to have marginalised communities who are most at risk and sits contrary to the NEMA principles and to best practice standards for public consultation in environmental law. 

  • TOURISM

Kavanagh et al (2019)  have shown that seismic surveys reduce cetacean sightings across a large marine ecosystem [xviii] , which has serious potential to affect tourism in the Transkei area. 

The Wild Coast is one of the best destinations worldwide for watching marine wildlife, including whales, both from land and/or from boat. Larger species such as humpback and southern right whales are semi-migratory and other species that will be in the survey block (December to April) which will be affected such as the deep diving beaked whales, Bryde’s whales and sperm whales. A wide variety of marine and coastal resources are at risk from displacement caused by this offshore survey, including such social resources as the tourist industry and the continued integrity of coastal communities.

There has been no Cost Benefit Analysis for this application. Consequences to the tourism, fisheries and recreational industries have not been properly considered. 

Contemporary research such as The Economic Contribution of the Ocean Sector in South Africa (Hosking et al 2014) as well as the Review of Ocean Economy Activities within the South African Exclusive Economic Zone with Particular Reference to the Offshore Oil and Gas, Fishing and Mining Sectors (Ken Findlay; CPUT Research Chair: Oceans Economy, July 2018) finds flaws with the valuation of the oil and gas sector which was undertaken by the Operation Phakisa consultancy firm, McKinseyi and which is presented in the Phakisa Document (Offshore Oil and Gas Exploration: Final Lab Report for Operation Phakisa). 

  1. DELETORIOUS EFFECTS TO MARINE LIFE

It appears that marine seismic surveys are allowed to be conducted in South Africa as there is an assumption is that impacted species will move away from the sound source[xix].  This is not correct as recent studies disprove this assumption[xx] and reveal a growing concern for those animals that are unable to avoid the airgun arrays.

Seismic surveys have the potential to exert significant deleterious effects, both at short range and long range[xxi] on the physical health, behaviour, distribution, communication, feeding, and social dynamics of marine mammals, particularly cetaceans.  There is extensive scientific literature documenting the effects of underwater noise, including oil exploration seismic arrays, on marine organisms, in particular marine mammals[xxii],[xxiii],[xxiv],[xxv],[xxvi],[xxvii],[xxviii].

These effects can include hearing loss (temporary or permanent), masking of communication, physiological stress, acoustic resonance in air cavities, organ rupture, behavioural responses, avoidance of critical habitat areas, decompression sickness, and mass strandings[xxix],[xxx].

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[xxxi]; massive hearing trauma in four squid species[xxxii], increased stress signals[xxxiii],[xxxiv],[xxxv],[xxxvi]; disruption in schooling and migration[xxxvii]; disruption of homing or orientation[xxxviii]; decreased feeding efficiency[xxxix]; and reduced catch rates of 40-80% in areas more than 30 km from seismic surveys[xl],[xli],[xlii].

It appears that there is support by the State for seismic survey activities to take place on an annual basis, creating chronic underwater noise pollution in the oceans for months at a time. Stress in marine mammals related to anthropogenic noise exposure has been conclusively proven, and prolonged exposure to noise stressors is known to cause significant impacts to marine mammals (Wright et al., 2007). 

The provisions of NEMA, and of the Constitution demands a critical and more thorough review of any suspected risk by all relevant government departments and organisations. 

  1. FAILURE TO CONSIDER ALTERNATIVE SOURCES OF ENERGY 

It is trite that alternative sources of renewable energy could replace the utilisation of fossil fuels, replacing South Africa’s aging and inadequate power generation capacity whilst at the same time spurring economic growth and cutting emissions. I refer you to the comments made by Valli Moosa, the deputy chairman of the Presidential Climate Change Coordinating Commission.  It is also trite that there is a growing universal trend by financial institutions to express their collective reluctance to finance fossil fuel projects.

On the basis of this alone the authority should be reconsidered to include the investigation of alternate sources of energy.

  1. CONSTITUTIONALITY OF THE ONE ENVIRONMENTAL PLAN WRT SEISMIC SURVEY 

The exploration right was secured in 2013, prior to the application of the One Environment System on 8 December 2014. 

For the Minister of Mineral Resources to authorise seismic applications that no longer required Environmental Impact Assessments was contrary to the provisions of the National Environmental Management Act and of the provisions of the Constitution. 

The provisions of NEMA, and of the Constitution, demands a critical and more thorough review of any suspected risk by all relevant governmental departments and organisations. 

            CONCLUSION

For all the reasons stated above it is our contention that the authorisation would not have been granted had the relevant authorities been privy to the science and circumstances which have come to light since the original EMPr was authorised and as such we reiterate our request that the decision to grant the permit referred to above be reconsidered and set aside and that the proposed reconnaissance survey be halted.

The aforementioned list of reasons is not exhaustive and we reserve our right to include additional reasons for our contention that the entire process should be revisited. 

In conclusion, we advise that it is our intention to proceed in terms of the provisions of MPRDA, read with the provisions of PAJA and of the Constitution in due course should a satisfactory response not be forthcoming by close of business on 3 December 2021.

Kindly be advised accordingly.


[i] Weir 1, C.R. and Dolman 1, S.J., 2007. Comparative review of the regional marine mammal mitigation guidelines implemented during industrial seismic surveys, and guidance towards a worldwide standard. Journal of International Wildlife Law and Policy10(1), pp.1-27.

[ii] Nelms, S.E., Piniak, W.E., Weir, C.R. and Godley, B.J., 2016. Seismic surveys and marine turtles: An underestimated global threat?. Biological conservation193, pp.49-65.

[iii] Parsons, E.C.M., Dolman, S.J., Jasny, M., Rose, N.A., Simmonds, M.P. and Wright, A.J., 2009. A critique of the UK’s JNCC seismic survey guidelines for minimising acoustic disturbance to marine mammals: Best practise?. Marine Pollution Bulletin, 58(5), pp.643-651.)

[iv] International Whaling Commission. Oceans Noise. [online] Available at: https://iwc.int/anthropogenic-sound, [Accessed 31 Oct 2018].

[v]  See After the Storm: Barriers to recovery one year on from Cyclone Idai, (2020).

[vi]  See Pienaar & Boonzaaier, 2018; Sousa et al., 2018; Mahlalela et al., 2019; Burls et al. 2019; Mahlalela, Blamey, Hart et al., 2020 and Western Cape Government, 2020 for the effects of ongoing drought in the Cape.

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

[viii] Energy Outlook, supra note 39, at 241.

[ix] Energy Outlook, supra note 39, at 241.

[x] Swanson, C., Levin, A., Mall, A. (2020) Sailing to Nowhere: Liquefied Natural Gas Is Not an Effective Climate Strategy. Natural Resources Defense Council.

[xi] Tollefson, J., 2017. Air-gun blasts kill plankton. Nature: International Weekly Journal of Science, (7660).

[xii] Jónasdóttir, S.H., Visser, A.W., Richardson, K. and Heath, M.R., 2015. Seasonal copepod lipid pump promotes carbon sequestration in the deep North Atlantic. Proceedings of the National Academy of Sciences112(39), pp.12122-12126.

[xiii] McCauley, R. D., et al. 2017. Widely used marine seismic survey air gun operations negatively impact zooplankton. Nature Ecology & Evolution 1(0195): 8.

[xiv] Wright, A. J., Aguilar-Soto, N., Baldwin, A. L., Bateson, M., Beale, C. M., Clark, C., et al. (2007). Do marine mammals experience stress related to anthropogenic noise? Int. J. Comp. Psychol. 20, 274–316. doi: 10.1152/ajpendo.00070.2006.

[xv] Engås, A., Løkkeborg, S., Ona, E. and Soldal, A.V. (1993) Effects of seismic shooting on catch and catch-availability of cod and haddock. Fisken og Havet, nr. 9. 117 pp. 

[xvi] Shinovene I. 2013. Govt fears tuna depletion as oil and gas exploration chase fish away, The Nambian, Nambia (25 November 2013) at: http://www.namibian.com.na/indexx.php?archive_id=116959&page_type=archive_story_detail&page =1

[xvii] McCauley, R. D., et al. 2003. High intensity anthropogenic sound damages fish ears. Journal of the Acoustical Society of America 113: 638-642.

[xviii] Kavanagh, A.S., Nykänen, M., Hunt, W., Richardson, N. and Jessopp, M.J., 2019. Seismic surveys reduce cetacean sightings across a large marine ecosystem. Scientific reports9(1), pp.1-10.

[i]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. 

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

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

[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, L. E., Ladich, F. Dittami, J. 2006. Noise, stress, and cortisol secretion in teleost fishes. Biological Conservation128, 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]Hildebrand, J. 2006. Impacts of anthropogenic sound. 101-123 in: Ragen, T.J., Reynolds III, J.E., Perrin, W.F., Reeves, R.R., and Montgomery, S. 2006. Marine Mammal Research: Conservation beyond Crisis. Baltimore: Johns Hopkins.

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

[xix] Boyd, A. Overview of seismic surveys and phosphate mining developments off South Africa’s coasts WG 8 prep-meeting on 22 April 2014, OR Tambo.

[xx] McCauley, R.D., Duncan, A.J., Penrose, J.D., et al. 2000. Marine seismic surveys – a study of environmental implications. APPEA J 40, 692–706.

[xxi] Madsen, P. T., et al. 2006. Quantitative measures of air-gun pulses recorded on sperm whales (Physeter macrocephalus) using acoustic tags during controlled exposure experiments. Journal of Acoustic society of America120(4): 2366-2379.

[xxii] Yazvenko, S. B., McDonald, T. L., Blokhin, S. A., Johnson, S. R., Melton, H. R., Newcomer, M. W., Nielson, R., et al. 2007. Feeding of western gray whales during a seismic survey near Sakhalin Island. Russia. Environ Monit Assess 134, 93–106.

[xxiii] Erbe, C., King, A. R. 2009. Modelling cumulative sound exposure around marine seismic.  J Acoust. Soc. Am. 125, 2443–2451. 

[xxiv] Breitzke, Monika & Bohlen, Thomas. 2010. Modelling sound propagation in the Southern Ocean to estimate the acoustic impact of seismic research surveys on marine mammals. Geophysical Journal International. 181, 818-846. 

[xxv] Gray, H., van Waerebeek, K. 2011. Postural instability and akinesia in a pantropical spotted dolphin, Stenella attenuata, in proximity to operating airguns of a geophysical seismic vessel. J Nat Conserv 19, 363–367.

[xxvi] Hildebrand, J. 2006. Impacts of anthropogenic sound. in: Ragen, T.J., Reynolds III, J.E., Perrin, W.F., Reeves, R.R., and Montgomery, S. 2006. Marine Mammal Research: Conservation beyond Crisis. Baltimore: Johns Hopkins. p101-123

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

[xxviii] Weir, C. R., Dolman, S. J., 2007. Comparative Review of the Regional Marine Mammal Mitigation Guidelines Implemented during Industrial Seismic Surveys, and Guidance Towards a Worldwide Standard. Journal of International Wildlife Law and Policy, 10,1–27

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

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

[xxxi] 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.

[xxxii] André, M., Johansson, T., Delory, E., van der Schaar, M., Morell, M. 2007. Foraging on squid, the sperm whale mid-range sonar. Journal of the Marine Biological Association UK 87, 59–67. 

[xxxiii] 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

[xxxiv] 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). Aquatic Conservation, 18, 1315–1324.

[xxxv] 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 offshore experimental seismic prospecting. Marine Pollution Bulletin, 38, 1105–1114 .

[xxxvi] Wysocki L.E., Ladich F., Dittami J. 2006. Noise, stress, and cortisol secretion in teleost fishes. Biological Conservation 128, 501–8.

[xxxvii] 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 

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

[xxxix] 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. 

[xl] 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

[xli] 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.

[xlii] 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

ANNEXURE A

Affiliated Organisations

  • African Conservation Trust
  • AfriOceans Conservation Alliance
  • 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
  • KZN Conservancies

Commercial

  • Shark Warrior Adventures
  • Ufudu Flyfishing Safaris

International

  • Parley For The Oceans

One thought on “Letter to the Ministers Leave a comment

  1. Brilliant Action and congratulations With such detailed legal Arguments and facts and Proof that the Truth will Always winn !!!

    Like

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