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Noise, toxins + pollution for 2 Years

TEEPSA Drilling in Block 5/6/7 between Cape Town and Cape Agulhas

Pic:Port Nolloth Small Scale Fishers Objecting to the Total Onslaught

Here are Oceans Not Oil’s objection and comments on the proposed exploratory drilling of 5 wells on the South West Coast offshore of Cape Town.

It also serves to highlight numerous failures and issues in need of review within this ESIA, listed below

  1. TIME FRAMES
    a) Time frames and duration are being downplayed, the physical drilling and testing will take, at best 2 years to complete. It is stated that it will “take approximately three to four months to complete the physical drilling and testing of each well (excluding mobilisation and demobilisation)”. The duration needs to be more transparent, i.e., by simple calculation: 

Mobilisation. =         45 days (x5 wells) =             225 days

Drilling =         90 days per well (x5 wells) =       450 days

Demobilisation. =         10 days (x5 wells) =               50 days                  

Total In Situ Duration = 725 days (~2 years)

b) 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.

    c) 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

5.1.2.1 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). 

a) 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. 

b) 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 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.

5.2.3. 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.

5.2.4. Draft Integrated Energy Plan (2013) 

The ESIA highlights further contentious 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.

5.2.9. 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]

6.4.5. Demobilisation and Well Abandonment

a) It is not sufficient for the Environmental Assessment to claim that well plugging “lasts a lifetime”. Well failure is a common enough issue[xii] 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.

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

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 FLAWS

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. 

a) The need and desirability of the project have not been addressed according to guidelines(Guideline on Need and Desirability, 2017) wherein it states, “it must be decided which alternatives represent the “most practicable environmental option”, which in terms of the definition in NEMA and the purpose of the EIA Regulations, are that option that provides the most benefit and causes the least damage to the environment as a whole, at a cost acceptable to society, in the long-term as well as in the short-term.”

b) Offshore hydrocarbon exploration whose ultimate aim is the consumption of oil and methane gas in the years to come, is no longer a practice in societal development. The Scientific Advisory Group on Emergencies (SAGE), Academy of Science of South Africa (ASSAf) have weighed up the systemic risks of this aim as it relates to ocean systems and the climate crisis showing that it will increase climate harms, 

i. altering winds, water temperatures, sea ice cover and ocean circulation;[xiii][xiv] 

ii. ocean acidification, which is now irreversible for centuries to come[xv][xvi][xvii] 

iii. altering the physiological functioning, behaviour, biological interactions, and productivity of organisms, which, in turn, could lead to shifts in marine life size structure, spatial range, seasonal abundance, community structure and ecosystem function;[xviii] 

iv. transferring nutrients from surface waters down into the deep ocean, leaving less at the surface to support plankton growth;[xix] 

v. potentially suppressing marine biological productivity for a millennium;

vi. ultimately destroying the fisheries and marine tourism industries of all countries, including South Africa, resulting in devastating job losses, food insecurity, and other adverse socioeconomic consequences;[xx][xxi]

c) plus increase economic costs, and injustice will undermine the immediate realisation of viable alternatives (Singh. J et al, 2022). Ongoing threats from GHG emissions include,

vii. ocean deoxygenation[xxii]

viii. sea level rise.[xxiii]

d) Impacts on coral reefs from marine heat waves (1980 to 2020) encompass coral bleaching records from 14 405 sites in 93 countries[xxiv]. Since coral reefs create coastal protection, which provides food and income to humans, their destruction has systematic consequences. The top part of the ocean is warming up 24% faster than it did a few decades ago, and this is accelerating. 

e) The Global Coral Reef Monitoring Network (GCRMN) report on The Status of Coral Reefs of the World: 2020, utilising data from over 12,000 collection sites across 73 countries spanning from 1978 to 2019, claims the world has lost about 14% of its coral reefs since 2009. Over 25% of the ocean’s fish and over half a billion people currently rely on healthy coral reefs. 

f) 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. 

With this climate science as the actual baseline for this project, It is clear that there is no “need’ for this project in terms of the broader societal/ public interest nor in terms of the well-being of future generations. In fact, due to South Africa’s sensitivity to climate impacts (and the ESIA has not acknowledged that climate change is likely to have a significant impact on South Africa’s economy) there is a categoric need not to pursue the project and that the choice of alternative energy cannot be another hydrocarbon option. 

Appraising this full ecological and socio-economic cost, including hazard and externality costs is imperative to establish no-go alternatives 

4. REQUEST RAISED DURING ESIA SCOPING MEETING, JUNE 2022

The request to supply the public with the EIA reports for the 2D seismic survey undertaken between 1 December 2012 and 11 February 2013 has still not been met. A 3D report was sent.

5.FAILURES 

a) Failure to identify the true scale of climate impacts: It is a fatal flaw in this SEIA that it has not drawn on the Sustaining the Wild Coast NPC & Others v Minister of Mineral Resources and Energy & Others, High Court of South Africa, Eastern Cape Division, Makhanda – Case No. 3491/2021, to produce a climate impact assessment. Without such an assessment, there is a severely understated existential risk to present and future generations. The ESIA, therefore, fails to place all relevant considerations before the decision-maker, as contemplated under Section 6(2)(e)(iii) of the Promotion of Administrative Justice Act.

b) 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 ESIA report has failed to identify, predict or quantify the actual or potential impact on the socio-economic conditions of these areas, despite the oil spill model indicating that accidental spills will reach the coastline;

ii. The potential of an accidental spill reaching the coastline is downplayed;

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

c) 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[xxv],[xxvi].

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. CLIMATE CHANGE AND AIR EMISSIONS 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).

8. UNDERWATER NOISE  

a) The ESIA acknowledges that the noise generated by vessels, well-drilling operations and the Vertical Seismic Profiling (VSP), falls within the hearing range of most fish, mammals and reptiles and would be audible and detrimental (risk of physiological injury or behavioural changes) for considerable ranges before attenuating to below threshold levels. While it is acknowledged, and ignored, by putting it aside due to pitiful mitigation measures, the actual cost to fisheries and tourism remain to be down-played and no attempt has been made to solve the problem at hand. The problem being that virtually no ocean noise research has been undertaken within South Africa. At what point is industry going to take responsibility in solving this massive and reoccurring issue together with the relevant national government environmental and fisheries departments? 

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

c) Please include the number of airguns being used.

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

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. DRILLING DISCHARGES MODELLING

a) The modelling acknowledges a high environmental risk (at Point 1) where maximum concentrations of cuttings, Barite and Bentonite calculated at the end of operations for each season are high, and the concentrations of the main contributor to the chemical risk (fatty acid in the EZ MUL NT and in the INVERMUL NT) are lower than the weighting agents but very superior to their PNEC values. It is concerning that the following line was inserted into the interpretation of the impact of the discharge modelling results “The calculated risk has also to be balanced because of the very conservative approach used in the model”. This line suggests that best-case values to potential risks were used in the modelling and gives false sense of risk, while down-playing the actual threat. 

b) A rough chemical composition of the drill cuttings and various discharges are given in the report. However, the implications of these cuttings and discharges being disturbed, and releasing these chemicals, some of which are known to be of high environmental risk, months or years after the operations are not mentioned. 

c) Furthermore, given the grain size of the drill cuttings and various discharges will be different to that of the seabed, the implications of smothering and change of benthic communities and infauna within these areas are not interrogated. 

10. OIL SPILL MODELLING

a) The interpretation of the oil spill modelling in the impact assessment document severely downplays the oil spill modelling report.  

The probability of oiling on the coastline is actually quite severe: 

i. Season 3 has the highest shoreline probability of oiling (up to 99%) assumably due to stronger northward currents and winds from NW, especially during June and July, driving the oil towards the shoreline in an easterly direction. Consequently, west coast of Cape Peninsula has the highest probability of impact during winter.

ii. Season 2 and Season 4 have a significant shoreline oiling probability (up to 89% and up to 83%, respectively).

iii. Season 1, the shoreline oiling probability is the lowest (up to 60% in general, and up to 15% for west coast of Cape Peninsula) due to NW surface currents (Benguela Current) and predominant winds from the SE, driving the oil towards offshore waters.

iv. Arrival time of spilled surface oil to shore between 1 and 20 days.

v. For Release Point 1 the most impacted shoreline would be the coast from St. Helena Bay to the Cape Peninsula, including North of Cape Town, and sometimes further south reaching Hermanus. 

vi. For Release Point 2, the most impacted coastline would be from Hermanus to Cape Agulhas.

vii. Additionally, an oil spill from Release Point 1 could reach the Namibian offshore waters (<5% of probability) and the Namibian shoreline (< 30% of probability), while an oil spill from Release Point 2 would not reach Namibian offshore waters and shoreline.

b) The probability of deep layer contamination is also severe, even though it’s accepted that dispersant decreases the size of the droplets, reducing the speed of ascent to the surface, thereby increasing the presence of oil in the deep layers, especially close to the release point. Therefore, the contamination area and the depth of contamination are: 

i. At Release Point 1 there is a 90% probability of contamination up to 18 km (with a maximum distance of 61 km to the south east, and 114 km to the north west). Up to maximum depths of 400 – 420 m

ii. At Release Point 2, the contamination area extends up to 18 km south east (90% probability for Season 1), but with a maximum distance of 62 km south east for Season 4, and maximum depths of 980 – 1 000 m.

c) Therefore Season 1 is the ‘best-relative-to-shore-based-life’ period to have an oil spill – with the lowest amount of oil onshore (especially January and February) due to the main surface currents towards the W-NW and winds from the SE that drive the oil spill towards NW, avoiding the coastline. If a spill starts between the end of January and beginning of March, there is almost no oil onshore. While Season 3 is the worst period with the highest amount of oil onshore, this is due to the main surface currents towards N and NW and winds from NW to SE that drive the spill towards N and E directly on the coast.

d) Furthermore, the predicted quantity of oil expected to reach the shore is not highlighted in the impact assessment document. Even in the best-case scenarios, where minimum values are used (757-4414 tons of onshore oil) will devastate fisheries and coastal community livelihoods. 

i. Given that drilling operations will be for approximately 2 years and accidents are unpredictable, these results should be clearly indicated to coastal communities, they are currently lost in a technical report.

ii. An assessment of the receiving onshore environment of oil 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.

11. 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-casescenario time period must be deliberated. Saying that Deepwater Horizon will never happen again because technology has advanced since that spill is equivalent to the Captain of the Titanic saying it cannot sink. 

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

12) MARINE ECOLOGY REPORT

a) The residual impacts on marine habitats and communities associated with the proposed drilling activities are given together with 43 main mitigation measures. It is of concern that these mitigation measures are, at best, suitable but there is no guarantee that TEEPSA during their activities will implement any of these measures, unless they are specified in their operational conditions/ permit. There are too many (43) of these measures to be specified in a permit condition, it is not understood how all these measures can be ensured.  

b) Similarly, how will the 28 mitigation measures be applied to the residual impacts on marine habitats and communities associated with possible unplanned events associated with the proposed drilling activities.

c) All the ROV data and videos – presumably this will be embargoed as with all bathymetric and seismic survey data that TEEPSA and partners have gathered. These data, specifically the ROV footage should be placed in the national biodiversity catalogue and be available online as a gesture of goodwill from TEEPSA. Providing it to institutions such as the South African National Biodiversity Institute or the Department of Forestry, Fisheries and the Environment with no-share or no-access conditions is not in the spirit of enhancing South Africa’s marine biodiversity and biological resource knowledge.

NOISE

It is acknowledged that while equipment is in water, the “noise produced will be low relative to the drilling noise and the dynamic positioning system (DPS)”.

a) Does this include the Vertical Seismic Profiling? 

i. And how does that compare to the noise cumulatively to the DPS and the drilling operations?

SPECIES LISTS

a) The use of the IUCN Red List categories (global and national/local), Threatened or Protected species (TOPS) categories, and endemism is used inconsistently in the various tables. The endemism status for all chondrichthyans is missing, while many of the IUCN categories are out dated and incorrect. 

b) Furthermore, some of the shark species were included in maps, most of these are not those which are threatened according to the IUCN, i.e., no Critically Endangered chondrichthyans are included. 

c) Moreover, according to the IUCN, categories CR, EN and VU are regarded as threatened. The VU category is being downplayed. 

d) It is very concerning that the area of interest has the highest concentration of cetaceans in the great area. Given that the drilling activities are anticipated to occur for possibly more than 24 months, how are these activities going to account for migration periods?

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

a) 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. 

b) 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.  

c) 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. 

d) 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.

e) An evaluation of each of these MPA’s & EBSA’s has been completed as a paragraph each, their sensitivities and critical ecosystem functions have been identified, however, there is no concern and a simple lack of acknowledgement that these areas could be devastated by a blow-put or other accidents

f) Buffer areas surrounding the above areas have been noted but it remains unclear if these will actually be part of the operational plan or if they are a mere mention.

13. SOCIO ECONOMIC ENVIRONMENT.

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.”

a) A full Cost Benefit Analysis is required.

b) Furthermore, 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. 

14. FISHERIES ACTIVITIES 

The exploration activities will be undertaken for an extended period of time (~24  months). From the scoping report, the impacts on the various fisheries range from no impact to impacting substantially. 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. There is no evidence of the Fisheries sector being consulted, the Pelagic longline and demersal trawl are expected to be the most impacted by drilling and post-drilling phase.

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


[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 reviews92, 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 Letters10(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] Vignes, Birgit, and Bernt S. Aadnoy. “Well-Integrity Issues Offshore Norway.” Paper presented at the IADC/SPE Drilling Conference, Orlando, Florida, USA, March 2008.

[xiii] Moore, J. K., Fu, W., Primeau, F., Britten, G. L., Lindsay, K., Long, M., … & Randerson, J. T. (2018). Sustained climate warming drives declining marine biological productivity. Science359(6380), 1139-1143.

[xiv] Cheng, L., Abraham, J., Hausfather, Z., & Trenberth, K. E. (2019). How fast are the oceans warming?. Science, 363(6423), 128-129.

[xv] Poloczanska, E., Mintenbeck, K., Portner, H. O., Roberts, D., & Levin, L. A. (2018, February). The IPCC special report on the ocean and cryosphere in a changing climate. In 2018 Ocean Sciences Meeting. AGU.

[xvi] Feely, R. A., Doney, S., Cooley, S., & Greeley, D. (2010). Oceans acidification: present status and future conditions in a high-CO2 world. Oceanography22(4), 36-47.

[xvii] Zeebe, R. E., & Wolf-Gladrow, D. (2001). CO2 in seawater: equilibrium, kinetics, isotopes (No. 65). Gulf Professional Publishing.

[xviii] Doney, S. C., Ruckelshaus, M., Emmett Duffy, J., Barry, J. P., Chan, F., English, C. A., … & Talley, L. D. (2012). Climate change impacts on marine ecosystems. Annual review of marine science4, 11-37

[xix] Zhongming, Z., Linong, L., Xiaona, Y., Wangqiang, Z., & Wei, L. (2018). Climate change could alter ocean food chains, leading to far fewer fish in the sea.

[xx] Pörtner, H. O., Roberts, D. C., Adams, H., Adler, C., Aldunce, P., Ali, E., … & Birkmann, J. (2022). Climate change 2022: Impacts, adaptation and vulnerability. IPCC Sixth Assessment Report.

[xxi] Pörtner, H. O., Roberts, D. C., Adams, H., Adler, C., Aldunce, P., Ali, E., … & Birkmann, J. (2022). Climate change 2022: Impacts, adaptation and vulnerability. IPCC Sixth Assessment Report.

[xxii] Hausfather, Z. (2019, 27 June). Analysis: Major update to ocean-heat record could shrink 1.5C carbon budget. Carbon Brief. https://www.carbonbrief.org/analysis-major-update-to-ocean-heat-record-could-shrink-1-5c-carbon-budget

[xxiii] Pachauri, R. K., & Reisinger, A. (2007). IPCC fourth assessment report. IPCC, Geneva2007.

[xxiv] van Woesik, R., & Kratochwill, C. (2022). A global coral-bleaching database, 1980–2020. Scientific Data, 9(1), 1-7.

[xxv] 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)

[xxvi] 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 Oceanography137, 454-462.

It also serves to highlight numerous failures and issues in need of review within this ESIA, listed below:

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