Not Fit For Purpose: Searcher Basic Assessment Report

This is Oceans Not Oil comment on the Basic Assessment Report (BAR) prepared as part of the environmental impact assessment (EIA) for and an objection to the proposed speculative three-dimensional (3D) seismic survey by Searcher Geodata UK Ltd (hereafter Searcher) off the Western and Northern Cape coasts of South Africa, 256 km offshore of St Helena Bay, extending north along the western coastline to approximately 220 km offshore of Hondeklip Bay over a number of offshore oil and gas licence blocks – including blocks 12/1/274 ER, 12/1/343 ER, 12/1/339 ER and “Open Area”.

The objection is based on the following, inter alia:

1. PROCEDURAL IRREGULARITY

The MPRDA does not enable permitting of non-exclusive multi-client seismic acquisition. Section 74 subsection (1)(a) to (c) of the MPRDA defines the ’holder’ of a reconnaissance permit or exploration right as meaning ‘the person to whom such right or permit has been granted or such person’s successor in title’. Also s74(2)(b), of the MPRDA states requirements of a reconnaissance application include that, “no other person holds a technical co-operation permit, exploration right or production right for petroleum over any part of the area”.

Searcher is not the holder of the rights to blocks 12/1/274 ER, 12/1/343 ER, 12/1/339 ER, therefore Searcher holds these permitting rights unlawfully.

2. BASIC ASSESSMENT REPORT NOT FIT FOR PURPOSE

If the primary purpose of the BAR process is as stated, to “give effect to precautionary measures“ and support “on-going proactive mitigation and the duty of care to the environment” (BAR, p.1.) the issue of global warming, and mitigation which is crucial to limit changes in the climate system, ocean warming, its consequential acidification (National Academy of Sciences Committee on the Science of Climate Change, 2001) and oxygen loss (Laffoley & Baxter, 2019), sea level rise and ocean biodiversity loss (Laffoley & Baxter, 2019), due to greenhouse gas emissions, should be centralised within the scope of this study. Scientific consensus in IPCC reports (Rogelj et al., 2018; Masson-Delmotte et al., 2019) warns that continued oil and gas production exacerbates all these effects. That the link between this project, whose purpose is reconnaissance for the expansion, and sustained use, of fossil fuels, and these existential threats, has not been made with the effect to produce a ‘no-go’ option, renders this BAR not fit for purpose.

3. SOCIAL LICENSE TO OPERATE QUESTIONABLE

a. Where are the outcomes from the recommendation that Searcher reassesses its “social license to operate” and produce a Strategic Environmental Assessment?

b. The recommendation that “A representative from Searcher should consult with the traditional leadership of the affected communities to establish what their understanding of meaningful consultation is and how communities should be consulted in future” has not taken cognizance of the judgement in the Sustaining the Wild Coast and others VS the Ministers of Environment, Forestry’s and Fisheries and Mineral Resources and Energy and others, 2022 case clarifying that it is not the “traditional leaders” that should be engaged, but the community as a whole.

c. The SIA. (p.111.) states, “from a social perspective it is clear that the communities and majority of local people are opposed to the project.” Please show the studies that show that risk of social unrest can be mitigated by “education”, and not coercion, in the case where communities have made it clear they are against a mining activity. 

d. The use of the word ‘cooperation’ needs to be reassessed. If its left to communities to “develop and undertake safeguarding measures or plans to enhance the mitigation capacity of their intangible cultural heritage“ (BAR, p.31) when an invasive and deleterious activity threatens such.

e. Proposals to “enhance mitigation capacity of intangible cultural heritage sites” are vacuous and by pegging mitigation on “ensuring reduction of impacts on fish species” which “should indirectly positively impact the potential negative impacts on the cultural heritage of the communities to be impacted” (SIA. p.51), makes a mockery of spiritual and cosmological value that the sea holds for coastal, fisher, indigenous and First People communities, and gives a clear indication why Searcher is not welcome in West Coast waters.

4. NO BASELINE FROM WHICH TO MAKE DECISIONS

a. The BAR is filled with “unknowns”, “substantial gaps” and a lack of local baseline studies and information on many species and the effects of noise on these species. Singh et al. (2022) warn that “the relative paucity of data in the South African context does not equate to no harm nor a low likelihood of harm”.  This number of fundamentally significant unknowns affects the validity of the impact assessments, making ‘minimising impact to acceptable levels’ guesswork at best.

b. Although the marine specialist report highlights various impacts and threats to the marine environment, the impact significance is rated as ‘relatively low’ or ‘medium’. Despite evidence of known impacts, and the acknowledgement of no data or knowledge in the area with regards to some species; it would be interesting to understand what information or proof would be required to have the impact significant ratings increased to unacceptable levels? Would it be dead fish and mammals trailing behind these vessels? If so, this is an unreasonable expectation given that most of the impacts are medium to long term.

Searcher conducting “on the water” surveys of snoek response to seismic surveys is not mitigation but tantamount to a kill count. 

c. The Fisheries Specialist report gives the definitions of their various impact ratings, while the Marine Specialist report does not but uses the ratings of ‘very low’, ‘low’ and ‘medium’ impact significance extensively.

d. The Marine specialist report is substandard in terms of actual impact assessment. The report consistently acknowledges that the target area contains threatened (Critically Endangered, Endangered and Vulnerable) species from multiple and various groups of birds, mammals, reptiles, fish and Chondrichthyes. The rating of residual impact on species is merely based on opinion, because, apart from a single study on African Penguins (Pichegru et al. 2017), there has been no research in South Africa on seismic survey or offshore exploration impacts.

e. Furthermore, Marine Protected Areas (MPAs), Ecologically and Biologically Significant Areas (EBSAs), Critical Biodiversity Area (CBAs), Ecological Support Areas (ESAs) and Vulnerable Marine Ecosystems (VMEs) are highlighted but the survey area is at the edge of the EEZ and most likely the area where the least amount of research has been undertaken, together with the least amount of information available. Similarly, with fisheries, who struggle to enter these areas due to the cost of fuel – these areas are most-likely the only pristine areas left in the SA mainland EEZ (as identified in the CBA maps). It stands to reason that the impacts on fisheries and species may be high if these pristine areas were to be targeted.

f. South Africa’s critically 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. The scenario with the African Penguin is not only to illustrate that these animals are susceptible (but ignored up to now) to seismic surveys, but to show that even though civil society has been calling for more research and information of the impacts and threats of seismic surveys to the marine environment in South Africa for almost a decade, there is still no additional clarity or knowledge on threats and impacts.

5. REASONABLE APPREHENSION OF REAL HARM TO MARINE LIFE 

a. Which mitigation guidelines are being utilised?

b. Will a multi-beam bathymetric sonar survey be operating concurrently with the 3D survey?

c. Please confirm that the array will contain 20 airguns, as suggested in the NIA modelling.

d. It is concerning there is no mention of the following numerous studies on ocean noise and seismic surveys which provide insight into the nature and impacts of sound waves (including air gun pulses) in water, including Goold and Fish (1998), Cummings et al (2004), Madsen et al (2006), Nowacek et al (2015), Nelms et al (2016) and Hastie et al (2019).

NOISE

e. “It must be noted, however, that the sound level specifications for sound source arrays refer to sound levels in the vertical direction directly beneath the sound source array, generally near its centre, with nominal sound levels in the horizontal direction being ~10-20 dB lower“ (BAR, p.6. ). 
This is a reductive view of sound propagation that assumes transmission loss and does not provide thorough, robust information for understanding the consequences of impact on decision making. Prideaux and Prideaux (2016) show that, “As well as spherical and cylindrical spreading, another variable can impact how far sound will be transmitted. … The depth where the sound speed is at a minimum is called the sound channel axis. The speed gradient above and below the sound channel axis acts like a lens, bending sound towards the depth of minimum speeds. The portion of sound that remains within the sound channel encounters no acoustic loss from a reflection of the sea surface and sea floor. Because of this low transmission loss, very long distances can be obtained from moderate acoustic power (Urick 1983, p. 159; Lurton 2010, p. 58).”

f. The BAR recognizes that the adverse effect of prolonged noise trauma from seismic surveys may intensify and last for a considerable time after the termination of the sound source, however neither stress nor maladaptive neuroplastic changes within the central auditory pathway symptomatic of noise exposure induced tinnitus in marine animals are broached. Animal models of tinnitus show it is a complex perceptual phenomenon affecting the quality of life of those afflicted, and it must be remembered that this survey will be operational every 10 seconds for 24 hours a day for 4 months, frequently compounded by multibeam bathymetric sonar output. 

g. Stress in marine mammals related to anthropogenic noise exposure has been conclusively proven (Wright et al., 2007), and prolonged exposure to noise stressors is known to cause significant impacts in a number of species (Finneran et al., 2002; Romano et al., 2004;  Eckert et al. 1998; McCauley et al. 2003; Rolland et al. 2012). According to Singh et al. (2022) these studies indicate that chronic elevations of stress to the organisms in the ecosystems may cause metabolic maladaptation, suppressing growth, immune system function, thermoregulation and reproduction with implications for individual and population fitness.

h. Since October 2021, Cape fur seals (Arctocephalus pusillus pusillus) have been under duress, with die-offs of thousands of individuals. Their foraging areas include the continental shelf up to 120 nautical miles offshore (Shaughnessy 1979) and therefore within the vicinity of the survey. Additional stress from seismic activity at this time is inadvisable (Harris, Olbers and Wright, 2022).

i. Mitigation measures for turtles in seismic surveys include observers, but it is unclear how an observer would be able to observe these animals within the sound-affected area (at least 1.2km), especially as large animals such as whales are only observed 44% of the time at best. A second mitigation measure is to install turtle devices to prevent them from becoming entangled in the gear which is likely to be somewhat effective for large turtles. 

j. Adult turtles may be less vulnerable to sound injury than cetaceans as the air spaces in their cochlear are smaller than those in cetaceans, making them less sensitive to sound shockwaves (Popper et al. 2014). However, while studies have shown that adult sea turtles have a moderate ability to move from an area being surveyed (Lenhardt, 1994; O’Hara and Wilcox 1990), they are prone to TTS after exposure to sound within 1 km of a sound source, with signs of recovery only two weeks after injury (Lenhardt, 1994). In a study undertaken on captive turtles, it was found that loggerhead turtles (Caretta caretta) responded to sound by swimming to the surface and remaining there or staying slightly submerged (Lenhardt, 1994).  It has been suggested that this could be explained by a sound shadow in the surface waters, where sound waves cancel each other out and the noise is at a minimum. Cummings et al. (2004) disputed this saying that although moving to near the surface could be an attempt for animals to take refuge, they are not in a ‘zone of silence’

k. Convergence zones of sound are not mentioned. 

ACOUSTIC INTENSITY/ BLAST PRESSURE INJURY

l. Oceans Not Oil notes in the Noise Impact Assessment (NIA) that Dr Jonathan Vallarta, Underwater Acoustics Business Lead of SLR Consulting (Canada) Ltd, defers to Southall et al., (2019) to identify zones of impact for marine mammals and other species, yet chooses to ignore their advice to consider “the importance of contextual factors (e.g., spatial proximity, behavioural and reproductive state, natural history, ecological parameters) in response probability and magnitude (e.g., Ellison et al., 2012; Southall et al., 2019b)” and that different metrics of acoustic exposure may be relevant in different settings (e.g., Madsen, 2005; Southall et al., 2007, 2019a). 

m. Following from point l. above, 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 the 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.

n. Vallarta’s NIA modelling is done for a 24-hour period, with 20 airguns, and assumes the airguns are stationary. Vallarta has also chosen to model sites with upslope propagation that produce fast fading propagation, “whereas other signals may be detectable at ranges thousands of kilometres from the source when sound travels down the continental slope (McCauley et al., 2008; Duncan et al., 2013).” (Carroll et al., 2017), which means that his modelling is hardly “conservative” but rather an unrealistic best case scenario.

o. Pressure signatures from generated bubbles are not modelled.

p. Southall et al., (2019) accept “no such standards are available for marine mammal applications for long- term, sustained exposures when animals may be coming in and out of an area and exposures may be intermittent.” Had the NIA taken cognizance of the inundation of mining applications along this western seaboard of South Africa a more informed, realistic context may be better established instead of the myopic desktop study produced here. 

q. Vallarta has focused his Underwater Acoustics Modelling on Sound Exposure Levels (SEL) but acknowledges the profound effects of Sound Pressure Levels on a broad range of species: “physiological systems of marine animals potentially affected by noise include the vestibular system, reproductive system, nervous system, liver or organs with high levels of dissolved gas concentrations and gas-filled spaces. Noise at high levels may cause concussive effects, physical damage to tissues and organs, cavitation or result in rapid formation of bubbles in the venous system due to massive oscillations of pressure “.

r. Further detailing is needed with regard to the blast-related injuries from over-pressurization shock waves, especially for vulnerable and commercial species. The BAR states that “the array has an operating pressure of 2 000 pounds per square inch”, or 13789.52 kilopascals /137.9 bars. Water is non-compressible and thus, a blast wave in water propagates rapidly with a slow rate of dissipation (Stuhmiller et al., 1991; Phillips, 1986) and has a greater potential for injury than it does in air (Stapczynski, 1982). Primary blast injuries are characterized by anatomical and physiological changes from the direct inertial, or shearing, forces or reflective over-pressurization force impacting an organism/animal’s body surface, potentially causing tears in the skin and internal organs, then seriously displacing parts of the body, mainly inducing injury in gas-containing organs such as lungs, the gastrointestinal tract and auditory middle ear. Gaseous contents within tissues are suddenly compressed by the blast over-pressure, re-expand and release a large amount of kinetic energy. Primary blast injuries cause significant morbidity; but are easily overlooked and the onset of complications from brain, ear, eye, lung and abdominal organ damage can take place well after exposure. (Ketten, Lien, & Todd, 1993; Gordon et al., 2003; Weilgart, 2007; Santulli et al., 1999; Popper & Hastings, 2009; Erbe & King, 2009; Garret, 2016).

6. REPEATED, PERSISTENT OR CUMULATIVE EXPOSURE IMPACTS

a. TGS Geophysical Company and GX Technology Corporation have pending applications which both overlap Searcher proposed survey area and may occur simultaneously. 

b. 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 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 (IWC 2018)”. As such, the authority which forms the basis of this objection falls squarely within the objectives of the aforesaid resolution. 

c. To recommend a thumb-suck 40km buffer zone between possible concurrent surveys does not acknowledge Madsen et al. (2006) study finding of 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 the 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. 

Furthermore, if a 40km buffer for vessels is recommended then surely the same should apply to buffer zones for protected areas?

d. Surely not having concurrent surveys is the most reasonable mitigatory solution to minimizing the very real risk of displacement which could have far-reaching effects not only for whole, and vulnerable, animal populations, but also on fishing sectors and food security?

e. The impacts of unilateral and indiscriminate traumatizing noise exposure beyond the boundaries of the seismic safety zone (such as decreased foraging efficiency, increased energetic demands, reduced group cohesion, compromised ability to nurse calves, reduced ability to communicate, increased risk of predation and decreased reproductive success and hampered avoidance of anthropogenic threats like entanglement and bycatch) on already depleted populations experiencing the cumulative impact of multiple stressors, need attention. Parsons et al. (2009) warn that some of the more insidious, and potentially devastating, impacts arise through long-term, repeated, persistent or cumulative exposures.”

f. Cumulative acoustic limits should be established. These limits should be appropriately matched to the spatio-temporal 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 difficult for animals to avoid exposure.

g. According to Braithwaite et al (2015) increased offshore anthropogenic activities, such as offshore mining, are likely to generate additional energy costs to migrating humpback whale populations. Therefore, energy related to reproduction would be jeopardized because the demand for energy would be funnelled into other related survival activities such as having to travel greater distances to avoid an area and changing swimming speeds. While local disturbances to behaviour may be minor, the costs of repeated disruptions may accumulate over a long journey (such as a migration) and thus collectively have a major impact on the energy stores of the whales. Given the historical anthropogenic pressure (whaling) on the Humpback whale population and its recent population comeback, it is a disgrace that exploration will be occurring in their direct migration channels, thus disturbing and changing the behaviour of the population, at an unknown cost.  

h. The use of rest buffer temporal windows after surveys recognizes that the adverse effect of continuous noise exposure may intensify and last for a considerable time after the termination of the sound source. Surveys are operational every 10 seconds for 24 hours a day for 6 months, frequently compounded by multibeam bathymetric sonar output. Maladaptive neuroplastic changes within the central auditory pathway, symptomatic of noise exposure induced tinnitus, is not broached in any current mitigation. Animal models of tinnitus show it is a complex perceptual phenomenon affecting the quality of life of those afflicted. Mann et al (2010) claim that hearing impairment could play a significant role in some cetacean stranding events, and stranding events with causal links to seismic activity have been indicated in Humpback whales, Minke whales and beaked whales by Cucknell, Boisseau and Moscrop (2015).

7. IMPACTS TO FISHERIES

a. Although the Fisheries Specialist Report predicts that the Pelagic Long Line Fisheries will be affected by the temporary exclusion of fisheries from the safety zone, and that the sounds produced are within the hearing range of fish species, the impact significance is low negative. It is acknowledged that the seismic survey will reduce access to fishing grounds, which in turn could potentially result in a loss of catch and/or displacement of fishing effort (direct negative impact), for approximately ~120 days. 

b. Both the Fisheries or Marine specialist reports failed to acknowledge the behavioural traits of various commercial fish, which move up and down the water column in 24 hrs to forage, which could expose them to direct injury or mortal impacts. 

c. Neither sound nor fish respect boundaries on maps, and seismic surveys have been shown to scare fish away from their usual habitats. “Zones of exclusion” therefore are unreliable and create a false basis for analysis. 

d. 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 (Shinovene, 2013). 

e. Effects of air gun pulses on fish can range from serious injury at short ranges, where seismic noise has deafened fish several kilometres away from the air-guns with no recovery after 58 days (McCauley et al., 2003) massive hearing trauma in four squid species (Andre et al., 2007), increased stress signals (Buscaino 2010; Graham and Cooke 2008; Santulli et al 1999; Wysocki et al., 2006), disruption in schooling and migration (Sarà et al., 2007), disruption of homing or orientation (Simpson et al., 2010), decreased feeding efficiency (Purser and Radford, 2011) and reduced catch rates of 40-80% in areas more than 30 km from seismic surveys (Engås et al., 1996; McCauley 1994; Turnpenny and Nedwell 1994).

f. According to Russell (2018), the west coast tuna pole and line fishery showed localised impacts, disrupting fast swimming tuna migration flow by forcing them to move on. Where there are cumulative impacts from repetitive surveys in the same area, there is the possibility that tuna change their migration path. This has occurred off Southern Namibia tuna fishing grounds, where catches have severely declined since 2011, and in 2017 dropped off to non-commercial catch rates.

g. The destructive effects on eggs, larvae and fry by seismic surveys have been shown to impact fishing success (Engås et al., 1993). 

h. Airgun operations kill large swathes of plankton (Tollefson, 2017), the basis of the marine food chain, up to 1.2km from the sound source. Within a recent study area, zooplankton abundance dropped by two-thirds (McCauley et al, 2017). They believe that “it is highly probable that sig­nificant depletion or modification of plankton community struc­ture is occurring on the scale of 3D seismic surveys undertaken”. They 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.

i. 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 therefore helping to control climate change.

j. Without an SEA how will communities establish and dialogue around a compensation scheme and conditions to secure the on-going functionality of these fishing sectors and to avoid devastating capital losses in the event of a decline in catches or displacement of species or fisheries? 

8. MITIGATION MEASURES INADEQUATE

a. The BAR suggests that Searcher will/must comply with a variety of international protocols but none of these protocols are specific to underwater noise or specified in the available documentation. 

b. Prescribed guidelines cannot prevent harm to marine turtles and mammals, given the complex propagation of airgun pulses; the side-lobes of unknown energy and propagation of multibeam sonar operations, the difficulty of monitoring, in particular, the smaller, cryptic, deep-diving species, such as beaked whales and dolphins; limitations in monitoring requirements; lack of baseline data; and other biological and acoustical complications or unknowns. Furthermore, recent literature provides credible concern about ecosystem/food-chain impacts of seismic surveys, which may in turn have an impact on fisheries, the severity and localisation of which will depend on coincidences with spawning and juvenile recruitment events. It is strongly recommended that further studies on these impacts, in the South African context, are carried out in situ before proceeding with this seismic survey. 

c. Given the limitations with suggested detection of marine animal presence around a sound source in this BAR, namely the ineffectiveness of marine mammal observer (MMO) surveillance in darkness, obstructed visibility (e.g. 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).

d. The speed at which the ship moves plus duty cycle and beam shape of the equipment governs the number of pulses of a given intensity a point in the survey area will receive. Likewise, it governs the ability of animals to avoid the noise. These criteria need to be continually revised by onboard Marine Mammal Observers to ensure that they are up to date, precautionary, and take into account masking effects and other potential lower-level sub-lethal impacts to individuals and populations.

9. TECHNOLOGY ALTERNATIVES NOT MENTIONED

a. 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 (e.g. 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).

b. If EIMS is working towards implementing worldwide best practice mitigation procedures alternative survey technologies (Weilgart, 2013) including Wide Azimuth data acquisition and Marine Vibroseis have been developed that are likely to be less harmful and should be prioritized.

c. 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).

d. Airgun silencers reduce noise at the higher frequencies. They are made from acoustically absorbent foam rubber and significantly reduce noise levels above 700 Hz to a maximum of 6 dB with an additional increase in sound levels around 100 Hz. 

e. 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.

10. PROTECTED AREAS, ECOLOGICAL IMPORTANT AREAS AND CRITICAL BIODIVERSITY AREAS

Although the reconnaissance area does not directly overlap the six Marine Protected areas (Orange Shelf Edge MPA, Child’s Bank MPA, Benguela Muds MPA, Cape Canyon MPA, Robben Island MPA and the Southeast Atlantic Seamounts MPA) or Ecologically or Biologically Significant Areas, it is only logical that sound will infiltrate these areas given the known distances sound propagates through water. The proximity of these surveys to our environmentally significant areas poses a great risk to our marine commons and heritage, the economic importance of our fisheries, and leisure and tourism industries dependent on functional healthy oceans. The results of this BAR should indicate a 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 BAR based on minimal biological baseline data. 

It should be noted that in the Marine Specialist report (pp. 54 & 194), it is highlighted that the reconnaissance area is within a pristine natural and near-natural area. As the SANBI CBA report and maps indicate, these natural areas are candidates for international obligations for further marine protection within the South African EEZ, as part of the DFFE’s 30×30 obligations to the CBD. With this in mind, it is totally irresponsible and unacceptable that pristine areas be expected to succumb to short-term goals of pursuing a deadly energy source that is recognised must be left in the ground.

11. NO GO ALTERNATIVE NOT ASSESSED

A ‘no-go’ alternative on a project, which sole imperative is the ultimate output of fossil fuel emissions was not considered. That seismic surveys have previously been conducted in South African waters does not establish irrevocable precedent, nor legitimise such activities in perpetuity (Singh. J et al, 2022). 

Howarth et al., (2011, 2014) and (Howarth, 2021) have shown that the radiative forcing of methane means its larger global warming role (Howarth, 2014) than coal or oil “for any possible use of natural gas” (Howarth et al., 2012). Further pursual of this exploration right will not align with the third instalment of the IPCC’s Sixth Assessment Report (AR6) requiring “immediate and deep” cuts in emissions everywhere. 

For all the reasons stated above we object to this project application and believe that in the interests of present and future South Africans it should be rejected.

Snoek painting by Carolyn Watson

CITATIONS

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. 

Braithwaite, J. E., Meeuwig, J. J., & Hipsey, M. R. (2015). Optimal migration energetics of humpback whales and the implications of disturbance. Conservation Physiology, 3(1), cov001.

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

Carrol A.G., Przeslawski R., Duncan A., Gunning M., Bruce B. (2017) A critical review of the potential impacts of marine seismic surveys on fish and invertebrates. Marine Pollution Bulletin 114: 9-14. 

Cucknell, A. C., Boisseau, O., & Moscrop, A. (2015). A review of the impact of seismic survey noise on Narwhal & other Arctic Cetaceans.

Cummings, J., & Brandon, N. (2004). Sonic impact: a precautionary assessment of noise pollution from ocean seismic surveys. Greenpeace Report, 1-45.

Duncan, A. J., Gavrilov, A. N., McCauley, R. D., Parnum, I. M., & Collis, J. M. (2013). Characteristics of sound propagation in shallow water over an elastic seabed with a thin cap-rock layer. The Journal of the Acoustical Society of America, 134(1), 207-215.

Dunlop, R. A., Noad, M. J., McCauley, R. D., Scott-Hayward, L., Kniest, E., Slade, R., … & Cato, D. H. (2017). Determining the behavioural dose–response relationship of marine mammals to air gun noise and source proximity. Journal of Experimental Biology, 220(16), 2878-2886.

Eckert, S. A., Bowles, A., & Berg, E. (1998). The effect of seismic airgun surveys on leatherback sea turtles (Dermochelys coriacea) during the nesting season. Final Rep. to BHP Pet. Ltd.

Ellison, W. T., Southall, B. L., Clark, C. W., & Frankel, A. S. (2012). A new context‐based approach to assess marine mammal behavioral responses to anthropogenic sounds. Conservation Biology, 26(1), 21-28.

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

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