ONO Objects to 5 Oil wells offshore Cape Town

TEEPSA Offshore Blocks 5/6/7

This letter serves to lodge an objection to the proposed exploratory drilling. It also serves to highlight numerous failures and issues in need of review within this ESIAR, listed below:

1. CONTRADICTIONS
   a) Lack of consistency in time-frame applications for the ESIA renders it unreliable. Environmental and social impacts are measured only during the operation of exploration, whereas the Need and Desirability section extends effects into the future beyond the project. This creates a complete lack of parity for any rational comparison of impact, effects and makes the significant ratings therefore irrational and skewed.
   
   The lack of environmental benefits and paltry local social/community benefits of the exploration project need to be weighed against its considerable pollution risk to the marine environment, fisheries, local communities and to intangible heritage;
   or,

Potential production rents generated, earliest by 2030, must be weighed against: 

1. increased and more frequent climate change effects of further expansion of fossil fuel production, 
2. a production pathway diametrically opposed to Paris-compliant Carbon Budgets. Recent findings by Calverley, D., & Anderson, K. (2022) make it clear that for a 50% chance of not exceeding 1.5°C, less than 10 years’ worth of emissions space remains at current levels of global production and requires immediate and deep cuts in the production of all fossil fuels. By further ‘front loading’/increasing the gradient of our emissions pathway, through expanding production, we render steeper rates of fossil fuel reduction earlier. Their report “makes absolutely clear that there is no capacity in the carbon budget for opening up new production facilities of any kind, whether coal mines, oil wells or gas terminals”. ^[i]
3. In this context, it remains for TEEPSA to explain how the further production of hydrocarbons “are aligned to broader societal needs” (5.1, TEEPSA Block 5, 6, 7 ESIA report),
4. new capital investment in renewable energy, 
5. asset stranding^[ii],
6. the social costs of carbon, including monetising the impacts on human health and the cost to remedy it, 
7. protracting a just transition, 
8. potential Carbon Border Adjustments Mechanism sanctions imposed by Western trading partners, 
9. considerable pollution risks to the marine environment, fisheries, local communities and to intangible heritage.
   
   b) 5.2.6 National Climate Change Response White Paper (2014)

The claim that renewable energy and not fossil fuel /gas is ultimately recommended for climate change mitigation contradicts, but would also overarch, the Draft Integrated Energy Plan (2013) consideration of natural gas for power generation. 

2. UNRELIABLE ASSUMPTIONS

9.3.3  Determination Of Sensitivity 

The site sensitivity is considered to be LOW based on the results of the DFFE Screening tool. Therefore, no assessment would be undertaken as the proposed exploration drilling activities are located more than 60 km offshore.” In the context of the offshore environment, the screening tool is a mere tick-box exercise and has no relevance in this process. The tool is flawed, not designed or populated with adequate offshore data to give an accurate assessment of the offshore environment. The screening tool results should be dismissed.

5.1.2 South African Energy Sector and Energy Mix 
As the country’s economy grows, it is critical to ensure that energy resources are available, and that there is access to energy services in an affordable, reliable and sustainable manner, while minimising the associated adverse environmental impacts (DoE, 2019). 

i)It is trite that the adverse environmental impacts, including decreases in carbon emissions space/budget, of further hydrocarbon exploration with the view to production/consumption are of an existential scale. 

a) The ESIA relies on outdated assumptions by the NGP (2011) that natural gas is needed for peaking. The ESIA process should reflect up-to-date research upon which decision makers can rely:

i)Brown et al have shown the feasibility and economic viability of a 100% renewable electricity system for South Africa, meeting the ”energy needs of all citizens at all times” is “cost-competitive with fossil- fuel-based systems, even before externalities such as global warming, water usage and environmental pollution are taken into account”. ^[iii]

They have established that a 100% renewable-electricity system requires no ‘re- invention’ of the power system, rather only a “directed evolution of the current system is required to guarantee affordability, reliability and sustainability”. In far less than the 6 years ( see 1.b.ii) there could be sufficient renewable electricity generation and storage technology to convert entirely to renewables.

ii) In February, the National Business Initiative (NBI) — a coalition of 86 major companies, including Eskom, Sasol and Shell – published a study showing that the electricity sector likely needs just 17 petajoules (PJ) of gas a year until 2035. South Africa already imports 180 PJ a year from Mozambique, repudiating any demand for further exploration.

5.2.2 New Growth Path (2011) 
…Priorities in this regard included strengthening the regional integration of energy by undertaking urgent improvements in electricity interconnectors and exploring other opportunities for enhancing clean energy across central and southern Africa, including natural gas. 

a) Hartley et al (2019) have shown in their working paper Quantifying the Macro- and Socio-Economic Benefits of a Transition to Renewable Energy in South Africa that “removing the constraints on renewable energy deployment leads to increases in real GDP and employment under conservative renewable energy costs (and to greater ones under optimistic costs), despite a decline in coal production and employment”.

b) Please remove all misleading associations of natural gas with “clean energy” unless TEEPSA can assure South Africans, and indeed the global community, that they capture the emissions, literally and genuinely, alternatives to fossil fuels must act as energy alternatives.

i) Studies show further development of gas infrastructure is incompatible with the Intergovernmental Panel on Climate Change (IPPC) target of keeping global increases in temperature below 2°C^[iv]. This all begs the question of the employment outlook, a just transition, economics and plain logic in the South African context. South Africa has already warmed at around twice the rate of global warming^[v].

ii)Methane is one of the GHGs declared as a priority pollutant, and therefore subject to pollution prevention plans and various provisions of NEMA and NEMAQA. It is also covered in the SA National GHG inventory.

National Development Plan 2030 (NDP) (2013) 
The ESIA claims “Thus, the ongoing exploration of local natural gas reserves is a key action required to ensure that natural gas is a viable transitional fuel for use in the national electricity generation mix“.
This needs to be substantiated if,

a) The latest gas-to-power IPP round has been budgeted at R2.47/kWh, according to Eskom’s Multi-Year Price Determination (MYPD) submission which is significantly more expensive than Eskom’s MYPD renewable energy projects modelled at 79c/kWh? ^[vi]

b) There is no reasonable justification for paying more per kilowatt, especially since renewable costs are decreasing.

c) While gas is cheaper per petajoule (PJ) than diesel, gas requires a massive infrastructural spend, increasing pricing on low volume purchases of gas.

d) Gas is going to take longer to meet South Africa’s energy needs than other energy options.

e) The risk of stranding further jobs in the fossil fuel industry needs very serious consideration.

f) Global carbon budget imperatives demand that this feasibility must be compared to returns on the cost of investment in renewable power generation projected to 2050 and should include externalised costs of emissions and include monetising the impacts on human health and the cost to remedy it.

5.2.3 Draft Integrated Energy Plan (2013) 

The ESIA highlights further contentio us claims that “The use of natural gas for power generation is also considered as an option to assist South Africa to move towards a low carbon future given that natural gas has a lower carbon content than coal.” 

a) Whether gas can achieve substantial climate benefits in the transition from coal-based electricity is highly contentious^[vii]. That perception of gas climate compatibility was derived from the fact that gas burns cleaner than coal, generating roughly half of the carbon emissions. However, that calculation ignores the enormous volumes of methane^[viii] into the atmosphere up and down the supply chain – at drilling sites, compressor stations, pipelines, and liquefaction facilities. That calculation also ignores the energy used to transport it.

b) Recent findings on the extent of methane leakage from gas infrastructure undermine claims of environmental benefits over other fossil fuels^[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 transport it, it ultimately presents a significant threat to the climate.

c) The ESIA assumes well-run gas infrastructure. Cumulative emissions of nitrogen oxides, carbon monoxide and volatile organic compounds from new fossil gas plants in South Africa will add to the existing emissions and health impacts from the coal sector.

5.2.8 Integrated Resources Plan (2019) 
The potential availability of gas provides an opportunity to convert to closed-cycle gas turbines (CCGT) and run open-cycle gas turbine plants at Ankerlig (outside Cape Town), Gourikwa (Mossel Bay), Avon (Outside Durban) and Dedisa (Coega IDZ) on gas.

a) The CSIR Strategic Environmental Assessment (SEA) for the development of a Gas pipeline network for South Africa report indicates that Eskom do not have the financial resources to convert coal-powered power stations into gas-powered power stations. Please justify this statement.

b) OCGTs and CCGTs will become obsolete soon with the introduction of batteries and a concerted effort to decarbonise the national grid. Also advances in electricity system operation will also lead to less renewable (wind) curtailment, massively reducing the need for backup thermal generation.^[xi]

8.1. Environmental and Socio-Economic Interaction Matrix 

a) Scoping out public health and safety for “accidental hydrocarbon spills / releases (minor) waste management and air emissions” minimises the potential ecological risks, and the consequential impacts to lives and livelihoods of small offshore spills, and erases their actual impact as cumulative environmental hazards. This coastal region has a large informal economy as well as intangible heritage dependent on a healthy ocean. Since these are not benign events it is the exact purpose of the ESIA to assess for them to inform the development of mitigation measures and decision-making. 

b) A cost-benefit analysis for the region is imperative.

3. FATAL FLAW

5.2. Paris Agreement – United Nations Framework Convention on Climate Change (2015) 
As a signatory to the Paris Agreement, South Africa is required to investigate alternatives to existing industries which have high carbon-emissions. A shift away from coal-based energy production within the energy sector and increased reliance on alternative energy sources is therefore anticipated. “Natural gas, and in particular liquefied natural gas, has potential to play a role for Africa as a rich and reliable source of energy, which can serve as a bridging fuel on the path to the carbon-neutral goal of the Paris Agreement (Source: https://www.kslaw.com/blog-posts/the-paris-agreement-on-climate-change-implications-for-africa).

Using an opinion-piece-blog quote from law firm King and Spalding (an Oil and Gas Council Sponsor, “representing clients on structuring and developing energy projects in the LNG, hydrogen, renewables and traditional oil and gas sectors”^[xii] ) to justify the use of fossil gas as a bridging fuel, under the heading of the Paris Agreement, throws doubt on the credibility of the scientific basis of this report and speaks volumes about the serious, uncalculated social and environmental implications this ESIA ignores.

4. CONCERNS RAISED DURING ESIA SCOPING MEETING, JUNE 2022

a) There has been a lack of consultation with First Nations in the region. It is particularly important that all stakeholders, including KhoiSan communities, are provided with complete relevant information to allow for informed and impartial decision-making.

b) There has been a lack of consultation with aquaculture facilities in the region.

c) TEEPSA is now aware of concerns raised during the online meetings that the relevant seismic surveys to this project may have played a part in the increased strandings of Dwarf Sperm Whales (2020). 
Reference: Seakamela S.M., McCue, S.A. and Kotze, P.G.H. 2021. Unusual mortality level of kogiid whales between 2010-2020. Oceans and Coasts Annual Science report, 2020. DFFE Report #20. 54pp.

i)Please enlarge your species list to include all deep diving species and beaked whales (i.e. Dwarf Sperm Whales, Short-finned Pilot Whales and Cuvier’s beaked whales) since these species are acoustically sensitive and vulnerable to anthropogenic noise pollution and are resident in the region. The ESIA should consider observations that show how they actively select the shelf-break edge, indicating that this is an important foraging habitat for these species. Consideration should also be made for elevated levels of nitrogen (N₂) in deep diving whales making them more susceptible to anthropogenic disturbances. Short-finned Pilot Whales are frequently impacted by high levels of anthropogenic marine noise (Hohn et al.2006). 

d) Please supply the public with the EIA reports for the 2D seismic survey undertaken between 1 December 2012 and 11 February 2013.

e) Please supply the public with the EIA reports for the 3D seismic survey undertaken between 8 January and 24 April 2020.

f) 6.4.1 TEEPSA state of their strategy for future drilling “that its not limited to a specific seasonal window period” p71 

i)This region is heavily reliant on the presence of Southern Right and Humpback Whales for tourism. Whale breeding cycles must be taken into account for the timing of the project.

ii) Seasonality of fish spawning and Commercial and Small-Scale Fisheries must be taken into account for the timing of the project.

Duration, date and season of the project are the cornerstone considerations of any environmental assessment without which this ESIA is rendered entirely unreliable.

g) While it is understood that exploration will confirm the actual size of the play, capital investment is significant for this project and must therefore be based on a guiding estimate of its size. It is imperative that the public is given this estimate.

h) 6.4.5 Well Abandonment

It is not sufficient for the Environmental Assessment to claim that well plugging “lasts a lifetime”. Well failure is a common enough issue^[xiii] and serious. It is imperative that understanding of barrier regulations, standards and implementation is adequate and proactive. Well integrity failure could have catastrophic implications and incident prevention should be the highest priority.

Please advise as to which actual contractor will be used for well plugging.

5. FAILURES 

a) Failure to consider requirements of the Integrated Coastal Management Act in the Administrative and Legal Framework 

i) Considering the lack of baseline studies for the ESIA and how much is unknown, it is suggested that careful consideration is given to the potential gains and/or losses at the inter- and intra-species levels; changes in species abundances; loss of habitat; loss of physical connectivity between habitats, and ecosystems. While also taking into account the unknown impacts on seabed features as well as undiscovered species which will remain unaccounted for. Consequently, there is a need for planned, coherent, and consistent ecological data to inform this ESIA to develop robust physical and biological baselines. The effectiveness of implemented mitigation measures with well-designed and consistent environmental monitoring is a critical next step.

b) Failure to identify the true scale of climate impacts. 
Reference North Gauteng High Court ruling in Earthlife Africa Johannesburg’s (ELA) case against the Minister of Environmental Affairs, the Department of Environmental Affairs (DEA), and Thabametsi Power Company (Pty) Limited (8 March 2017)

c) Despite indicating that it would describe ‘key… socio-economic resources…… in areas potentially affected by the project‘ and ‘provide data to aid the prediction and evaluation of possible impacts’, 

i) the draft EIA report has failed to identify, predict or quantify the actual or potential impact on the socio-economic conditions of these areas;

ii) nor the entire coastline that may be affected by any environmental disaster associated with the project;

ii) nor have the impacts of a catastrophic spill on the broader South African economy been described or quantified.

d) Failure to include a dispersant use plan.

6. WASTES & IMPLICATIONS FOR REMEDIATION

a) It is misleading to describe lower toxicity NADF (Group III NADF) as “biodegradable and not persisting in the long-term” (6.4.4.3.2.), since there is research that shows that chronic intermittent exposure of species such as corals, shrimp, scallop, including larval stages of many species, to dilute concentrations of operational drilling wastes (characterised by tests as practically non-toxic) can affect growth, reproductive success and survival^[xiv],[xv].

i)At 3570m hypoxic conditions are likely to make biodegradation extremely slow (Rye et al. 2006a).

b) What assurances are there that drill cuttings will be treated to reduce oil content before disposable over board? 6.9% oil content is extremely high. 

c) Offshore thermal desorption offers an alternative method to treat drilled cuttings offshore and reduce the oil concentration on cuttings to typically less than 0.5% by weight prior to marine discharge. Is this a method being considered?

d) The Drilling Discharges Modelling Study must evaluate the contamination by not only 234 230 Kgs of Non-aqueous Drilling Muds per well, but also model for the risk of the cumulative exposure to toxic and non-toxic stressors (dissolution of the chemicals, transport and deposition of particles, biodegradation, attachment of chemicals to particles, and eventually formation of agglomerated particles), and the fates of the discharge compounds in the sediment (e.g., concentrations and biodegradation in the sediment, bioturbation, equilibrium partitioning for organic chemicals and heavy metals, oxygen content in the porewater, change of grain size, and burial) from 1.17115 tonnes of discharge from five wells. 

e) Please advise as to which actual licenced waste contractor will be used for disposing of volumes of NADF remaining from the project. It is understood that this option may not be used, but we believe it is in the public interest to know the name of the contractor should the option be employed.

f) Please advise as to which actual licenced waste contractor will be used for disposing hazardous wastes from the project, for the same reasons as above.

7. 6.4.6.4. AIR EMISSIONS /CLIMATE CHANGE AND IMPACT ASSESSMENT

a) TEEPSA’s estimate of 10 000 bbl oil to be flared per test, “i.e. up to 20 000 bbl over the two tests associated with an appraisal well’ needs to be expanded given that there may be up to five wells in total). A more realistic total estimate then stands at 100 000bbl or 15 899 000 litres of oil. To understand the carbon footprint of this oil TEEPSA/SLR need to provide an estimate of their carbon percentage, by weight. 

b) What carbon budget has been allocated by the Minister of Forestry, Fisheries and the Environment for this project? 

c) Has a greenhouse gas mitigation plan been prepared and submitted to the Minister for approval?

d) Total Energies and Shell have endorsed the Zero Routine Flaring by 2030 (Shell ZRF by 2025) initiative launched by the World Bank and the United Nations in 2015 for new field development, so what consequence does this hold for this operation?

e) The ESIA should suggest adopting integrated system engineering designs for reducing flaring, ( Bawazir, I. et al. (2014), Qatargas Flare Reduction Program, Society of Petroleum Engineers, presentation at International Petroleum Technology Conference, Doha, Qatar,) such as using it onsite for operational energy, or reinjecting it for pressure support or permanent disposal (IEA (2021), Flaring Emissions, IEA, Paris https://www.iea.org/reports/flaring-emissions).

f) Winds, which can reach 30-60 knots along this coastline, may affect flaring efficiency and requires consideration. 

8. 6.4.6.5 NOISE EMISSIONS 

a) What alternatives to Vertical Seismic Profiling have been investigated?

b) Please include the number of airguns being used.

c) Please include the decibel attenuation for the Vertical Seismic Profiling.

d) Please establish cumulative acoustics limits for relevant species

e) Recurring impacts along this section of coastline where there is a wide range of extractive activities and the possibility of concurrent seismic surveys, have not been considered, by the EIAR. Parsons et al. (2009) warn that some of the more insidious, and potentially devastating, impacts arise through long-term, repeated, persistent or cumulative exposures. 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.

f) The Underwater Noise Modelling Study also needs to establish a hearing threshold-based safety zone based on a Permanent and Temporary Threshold Shift is imperative to reduce the likelihood of physiological effects resulting in killing of individuals.

g) What international operational guidelines will be followed for mitigation of noise during this operation?

h) Please assess the full scale of this acoustic footprint including impacts caused by vibration through drill string and casing, vibration into the seabed, vibration of drill bit.

i) Please indicate any electromagnetic operations and the effects to vulnerable species eg. chondrichthyans.

9. 6.4.6.6 EMERGENCY RESPONSE 

a) Emergency response preparedness calls for plans for mitigating a worst-case scenario, not a reasonable response period of a 20-day installation of a capping stack. Considering depths of 3570m, a worst case scenario time period must be deliberated. 

b) Plans for worst-case scenarios such as an underground blow-out which cannot be contained using blow-out preventers must be also considered.

10. WELL LOGGING 
6.4.4.5.1 Radioactive sources may be used for certain types of data acquisition. 

a) Please identify, and declare the half-life/rate of radioactive decay,of the radioactive sources. 

b) Incidents involving radiation sources in well logging have occurred mainly as a result of operator error or equipment failure. According to the International Atomic Energy Agency 2020 Radiation Safety In Well Logging: Specific Safety Guide report the hazards involved and the necessary control measures should be identified for each of the following conditions:

i) Storage of the well logging sources
— Calibration and operation of the well logging tools; 
— Transport of the sources;
— Work at the site with the well logging tools;
— Maintenance of the tools;
— Disposal of disused sources. 

ii) The possibility of theft and sabotage of radioactive sources. 

Please identify control measures for these conditions.

11. MARINE PROTECTED AREAS (MPAS), ECOLOGICALLY AND BIOLOGICALLY SENSITIVE AREAS (EBSA’S), CRITICAL BIODIVERSITY AREAS (CBA’S) AND BUFFER ZONES

The MPAs in South African form a Network which covers 5% of the EEZ around South Africa. These areas are recognised and have documented special features, including representative, unique and sensitive ecosystems, their importance for providing sanctuaries for threatened species and their essential habitats, and their role in supporting rebuilding populations of over-exploited fish species. 

There are twenty-one MPAs which could potentially be impacted by the exploratory drilling, which may pose significant risk from minor operational leakages, spills and pollution and/or a major oil spill if there is a blow-out.  Two MPAs overlap with the Block, including Brown’s Bank and Southeast Atlantic Seamounts MPAs, while Offshore Marine Protected Areas adjacent to the area, including Orange Shelf Edge MPA, Namaqua Fossil Forest MPA, Child’s Bank MPA, Benguela Muds MPA, Cape Canyon MPA, Robben Island MPA, Agulhas Bank Complex MPA, Agulhas Muds MPA, South West Indian Seamount MPA. Coastal Marine Protected Areas adjacent to the area, included the Namaqua National Park MPA, Rocher Pan MPA, West Coast National Park MPA, Table Mountain National Park MPA, Helderberg MPA, Betty’s Bay MPA, Walker Bay MPA, De Hoop MPA, Goukamma MPA and Robberg MPA.  

There are also three Ecologically and Biologically Sensitive Areas (EBSAs). The principal objective of the Ecologically or Biologically Significant Areas (EBSAs) is identification of features of higher ecological value that may require enhanced conservation and management measures. Even though EBSAs currently carry no legal status. Block 5/6/7 overlaps with five EBSAs (namely the Cape Canyon and Associated Islands, Seas of Good Hope, Protea Seamount Cluster, Brown’s Bank and Benguela Upwelling System EBSAs), the Area of Interest for proposed exploration drilling avoids all EBSAs. 

There are also a number of EBSAs in the indirect area of influence: Orange Seamount and Canyon Complex EBSA, Orange Cone EBSA, Namaqua Fossil Forest EBSA, Childs Bank and Shelf Edge EBSA, Namaqua Coastal Area EBSA, Mallory Escarpment and Trough EBSA, Agulhas Bank Nursery Area EBSA, Shackleton Seamount Complex EBSA, Kingklip Corals EBSA, Tsitsikamma-Robberg EBSA.

a) A full evaluation of each of these MPA’s, EBSA’s, CBAs and their sensitivities are expected to be fleshed out in the ESIA. 

b)In addition, the buffer areas surrounding these areas are expected to be noted and added to the operational plan. 

12. 7.6 SOCIO ECONOMIC ENVIRONMENT.

a) The proposed exploration is not likely to create long-term jobs for South Africans; however, the proposed activities “could potentially affect fishing activities, as a result of fishing exclusion from the 500m operational safety zones around the drilling unit; increased underwater noise disturbance during drilling and Vertical Seismic Profiling activities, the abandonment of the wellheads on the seafloor.”vi 

Again we call for a full Cost Benefit Analysis.

b) Further, according to the Scoping Report, Southern right whales may be affected by the drilling while passing through the Block enroute to their coastal breeding grounds.vii Given that the noise and disturbance from the drilling may affect the presence and behaviour of cetaceans like Southern right whales, the drilling could affect tourism along the Whale Coast, which relies on the presence of these whales to generate tourism revenue for the region. 

13. FISHERIES ACTIVITIES 

a) A full analyses of the fisheries and their catch composition per month should be indicated in the ESIA so stakeholders can be fully briefed of potential impacts and implications of the fishing sector not being able to enter their fishing areas. 

b) The exploration activities will be undertaken for an extended period of time. From the scoping report, the impacts on the various fisheries range from no impact to impacting substantially. Evidence that the Fisheries sector have been fully consulted and are in full support of the exploration drilling should be written into the EIA. Up to now, fisheries appear to have had little to no say that their areas are being intercepted and they are expected to stay out of the areas. 

c) The fishery that will be the greatest impacted is most likely the tuna pole fishery. This fishery is the most ecologically and environmentally friendly fishery of all SA fishery types, but it is also the fishery where the catch season is between October to December which is within the exploration period. As per the scoping report, this fishery spends most of its time at sea searching for fish with actual fishing events taking place over a relatively short period of time. This fishery will be severely disadvantaged being unable to work in their operational areas.

14. 9.2.1.2 OIL SPILL MODELLING 

a) An assessment of Onshore Environment and Mitigation is needed. Buried oil contaminants can resurface as the beach erodes. Buried oil must be removed through mechanical excavation. The ESIA needs detailed modelling of cross-shore distribution of oil contaminants relating to beach morphodynamic terminology to help optimize beach clean-up planning.

For all the reasons stated above, it is our urgent request that the proposed exploration does not proceed.

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^[i] Calverley, D., & Anderson, K. (2022). Phaseout Pathways for Fossil Fuel Production Within Paris-compliant Carbon Budgets.

^[ii] Caldecott, B., Harnett, E., Cojoianu, T., Kok, I., & Pfeiffer, A. (2016). Stranded assets: A climate risk challenge. Washington DC: Inter-American Development Bank.

^[iii] Brown, T. W., Bischof-Niemz, T., Blok, K., Breyer, C., Lund, H., & Mathiesen, B. V. (2018). Response to ‘Burden of proof: A comprehensive review of the feasibility of 100% renewable-electricity systems’. Renewable and sustainable energy reviews, 92, 834-847.

^[iv] The Summary for Policymakers of the IPCC Working Group III report, Climate Change 2022: Mitigation of climate change. 2022.Intergovernmental Panel on Climate Change (IPCC) https://report.ipcc.ch/ar6wg3/pdf/IPCC_AR6_WGIII_PressRelease-English.pdf

^[v] 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(8),

^[vi] Comrie, S. (28 Jan 2022)  Stepping on the gas: Mantashe’s not giving up on his vision just yet. News24. https://www.news24.com/fin24/economy/stepping-on-the-gas-mantashes-not-giving-up-on-his-vision-just-yet-20220128

^[vii] Myhrvold, N. P., & Caldeira, K. (2012). Greenhouse gases, climate change and the transition from coal to low-carbon electricity. Environmental Research Letters, 7(1), 014019.

^[viii] Cusworth, D.H., Duren, R.M., Thorpe, A.K., Olson-Duvall, W., Heckler, J., Chapman, J.W., Eastwood, M.L., Helmlinger, M.C., Green, R.O., Asner, G.P. and Dennison, P.E., 2021. Intermittency of Large Methane Emitters in the Permian Basin. Environmental Science & Technology Letters.

^[ix] Swanson, C., Levin, A., Mall, A. (2020) Sailing To Nowhere: Liquefied Natural Gas Is Not An Effective Climate Strategy. Natural Resources Defense Council.

^[x] Ibid.

^[xi] ECF. (2019). Towards Fossil free Energy in 2050, p.6

^[xii] https://energycouncil.com/?s=Oil+and+Gas+Council+Sponsor

^[xiii] Vignes, Birgit, and Bernt S. Aadnoy. “Well-Integrity Issues Offshore Norway.” Paper presented at the IADC/SPE Drilling Conference, Orlando, Florida, USA, March 2008.

^[xiv] Shumway and Parsons, 2011 and 2016 /Chronic toxicity and physical disturbance effects of water- and oil-based drilling fluids and some major constituents on adult sea scallops (Placopecten magellanicus)

Cranford, P. J., Gordon Jr, D. C., Lee, K., Armsworthy, S. L., & Tremblay, G. H. (1999). Chronic toxicity and physical disturbance effects of water-and oil-based drilling fluids and some major constituents on adult sea scallops (Placopecten magellanicus). Marine Environmental Research, 48(3), 225-256.

[xv] Järnegren, J., Brooke, S., & Jensen, H. (2017). Effects of drill cuttings on larvae of the cold-water coral Lophelia pertusa. Deep Sea Research Part II: Topical Studies in Oceanography, 137, 454-462.