Oil/Gas Well Public Meetings a Farce – TotalEnergies, QatarEnergy, Canadian Natural Resources International South Africa Limited, and MainStreet 1549: TEEPSA 11B/12B

Here is Oceans Not Oil’s comment on the Draft Scoping report for TotalEnergies, QatarEnergy, Canadian Natural Resources International South Africa Limited, and MainStreet 1549 ‘s application to develop a series of up to 10 oil/gas wells and subsea platform with pipelines offshore from Cape St Francis to Mossel Bay.

-Drilling of up to six (6) development and appraisal wells on the project development area; Laying of deep-water subsea manifolds and flowlines connecting wells within the project development area; and
-Connection of these manifolds and flowlines to the existing PetroSA F-A Platform at Block 9 Offshore Field, via a subsea production pipeline of approximately 109 km in length.

This letter serves to comment on and lodge an objection to the TotalEnergies EP South Africa B.V. Draft Scoping on the Environmental and Social Impact Assessment (ESIA) and proposed public participation process for the proposed offshore production right and environmental authorisation applications for Block 11B/12B. It also serves to highlight numerous contentious issues with this EIA process. Our primary concern is that there is clear systemic injustice and fundamental flaws in the EIA process for this application, and as such WSP have failed to comply with the EIA requirements as set out in NEMA and the EIA Regulations, and this is evident for the following reasons:

The objection is based on the following, inter alia:

1. BIASED, UNFAIR & UNDEMOCRATIC PUBLIC PARTICIPATION PROCESS 

This application’s public participation process has been shown to be deeply flawed and undemocratic:

a) Loudhailing by municipal councillors was witnessed on the 16^th and 18^th of January in the Kwanonqaba formal settlement in Mossel Bay and in the Thembalethu formal settlement in George, announcing that jobs were available should the public arrive, sign in and attend the public meetings for this BLOCK 11B/12B application (Annexure A & B). 

Furthermore, at the Thembalethu public meeting on 18 January 2023 a participant approached the microphone saying that most of the people present at the meeting only came because they were promised jobs, but that they were confused by the stakeholder engagement because it had nothing to do with the jobs. Feeling that they had been misled, many left the meeting thereafter.

This inducement of the community in an effort to tick box a public participation meeting does not constitute meaningful engagement of the community by WSP.

b) A major deficiency is, and has been, the failure of this DSR regime to consider ethnodiversity. Many of the I&APs, attending the same Thembalethu public meeting on 18 January 2023,  do not speak English or Afrikaans with the proficiency required to fully understand the literature to grasp the implications of the project and how to address these. This needs to be tackled retroactively with immediate effect as this process has been fundamentally exclusionary. (Annexure A & B)

c) WSP did not democratically or fairly manage the Thembalethu public meeting on 18 January 2023 to prevent intimidation and racist comments by an ANC Councillor from Mossel Bay, of those who asked difficult questions or who offered critique. The same councillor threatened one participant outside physically. (Annexure A & B)

d) WSP consultants refused to include all inputs by participants on their whiteboard flipchart notes and when questioned about this, WSP declared the comments invalid. These inputs that were deemed “invalid” were critical of the project. (Annexure A & B)

As such WSP has failed to follow a procedurally fair process in accordance with Section 3 of the Promotion of Administrative Justice Act, (PAJA). Section 3(1) (a) of PAJA requires a procedurally fair process for administrative decision-making. This includes a reasonable opportunity to make representations about the subject matter being considered (section 3(2) (b)(1)). This opportunity to make representations, and is linked to the model of participatory and representative democracy in this country. 

2. NEED AND DESIRABILITY OF THE PROJECT  

a) To frame this project, which continues to expand and sustain the use of fossil fuels, which in turn exacerbate global warming and extreme climate events, as consistent with NEMA principles and as if NEMA principles (quoted in 4.4 of the ESIA) will guide the ESIA process, is an abuse of public trust.

It has been shown that Total (branded now TotalEnergies) “personnel received warnings of the potential for catastrophic global warming from its products by 1971, became more fully informed of the issue in the 1980s, began promoting doubt regarding the scientific basis for global warming by the late 1980s, and ultimately settled on a position in the late 1990s of publicly accepting climate science while promoting policy delay or policies peripheral to fossil fuel control.”^[i]

WSP promotes a ‘future scenario’ TotalEnergies as environmentally responsible with claims that its oil-based business model will help contribute “to the country’s strategic objective of moving to a sustainable economy” and “serve as a bridge on the path from reliance on fossil fuel to carbon-neutrality from 2050” without TotalEnergies making actual changes to this model. This DSR adds to TotalEnergies’ litany of denial and deflection of attention away from the willful global endangerment by promoting fossil fuel products. 

Methane’s (CH4) considerably higher global warming potential than carbon dioxide (CO2) (Holmes et al., 2013) makes it a substantial contributor to climate change. 2014 estimates suggest that CH4 emissions from oil and gas processes account for approximately 20% of worldwide anthropogenic emissions^[ii]. Emissions from oil and gas production activities have increased from 65 to 80 TgCH4.yr-1 ^[iii], [iv] in the last 20 years^[v]. This escalation jeopardises the success of the Paris Agreement^[vi]. Given the fact that the subject of any production right represents a significant threat to the environment and to biodiversity, not to mention the public’s constitutional right to an environment that is protected for the benefit of current and future generations, WSP lack of critical analysis in this regard demonstrates bias and an unjustifiable dereliction of duty.

b) This project has the potential to put the $8.5bn Just Energy Transition Partnership and future critical concessional loans, designed to support SA’s just transition from fossil fuels, at risk.

3. 2022 FAILURE OF OFFSHORE PIPELINE LEAK NEAR MOSSEL BAY NEEDS EXPLANATION

The scoping report has given no explanation for the leak, its quantity of condensate lost and the extent of environmental contamination, in the PetroSA condensate pipeline running from the offshore FA platform to the GTL refinery in Mossel Bay. It stands as a precedent; therefore it is imperative that the public is fully informed before further proceedings take place.

4. ALTERNATIVES REMAIN UNCONSIDERED

It cannot be denied that the actual alternatives to extraction of fossil fuels is an investigation into the use of renewable energy. 

a) Please supply energy alternatives to this project.

5. SOCIO ECONOMIC ENVIRONMENT 

a) That this project has the potential to exclude or reduce catch rates for large pelagic longline fisheries and small scale fishers for years could prove catastrophic for some of them. These fisheries spend most of its time at sea searching for fish with actual fishing events taking place over a relatively short period of time. These fisheries will be severely disadvantaged being unable to work in their operational areas. The significance of impact of both cumulative effects and extended duration should be considered high and compensation for loss of income must be established through an Cost Benefit Analysis.

b)Please support your view in detail, and in estimated increase to household income, of the “socio-economic benefits” of the project to local communities.

Given a recurring pattern of the ‘pre-source curse’ effect: increase indebtedness, corruption and instability frequently which follow major oil and gas resource finds, even before production begins^[vii], and which is playing itself out in Mozambique currently^[viii], this needs substantiation.

“In contrast to hopes for development, Mozambicans are now on average poorer than they were a decade ago. 75% of Mozambicans spend less that $1 per day, and 90% are under the international poverty line of $1.90. Cabo Delgado, where the gas projects are based and site of an ongoing violent conflict, has been hit the worst: household spending has dropped by 38% in the last 5 years. Inequality is rising: the richest 10% of population account for 43% of expenditure, while the poorest 10% account for just 0.8% – and are poorer than they were a decade ago.”^[ix]

6. MANAGEMENT OF ENVIRONMENTAL IMPACTS OF PETROLEUM EXPLORATION AND PRODUCTION 

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

There is no mention of a Cost Benefit Analysis or a Strategic Environmental Analysis for this application. Consequences of a blowout, or accidental release (and these happen as a matter of course during offshore operations) to tourism, fisheries and recreational industries need to be fully considered.

Despite numerous requests to DMRE and DFFE, there has been no Strategic Environmental Assessment (SEA) undertaken for offshore Oil & Gas in South Africa. Considering the potential for massive pollution being present, a rigorous, independent and proactive SEA should be undertaken to inform the environmental viability of this offshore oil and gas proposal.  

a) Please supply a Cost Benefit Analysis for this application.

b) Please supply a Strategic Environmental Analysis for this application.

7. OIL SPILL CONTINGENCY PLAN 

The Oil Spill Contingency Plan will need to be sufficient and based on South African waters and offshore conditions. Stakeholders and I&APs should be able to engage on whether or not this plan provides sufficient protection to associated tourism, fisheries and businesses which rely on a healthy marine environment. Transparency is needed with regards to Oil Spill Response, Planning and Capacity necessary for public health and welfare as well as that of the marine and coastal environment. 

In the blowout contingency plan, the deficit of technological expertise or resources or difficulty of effective co-ordination with all government and conservation agencies that have a statutory responsibility for some aspect of offshore oil and gas activities regarding incident management should be highlighted. Furthermore, the delegated National Incident Commander, along with the intended lines of responsibility for inter-agency efforts, should be made available for proper stakeholder and I&AP engagement. 

The citizens of South Africa need assurance that incident management is fully informed and that South Africa has capacity to deal with the latest technology, practices and risks associated with, and due to, the different geological and ocean environments being explored, prior to the commencement of drilling.

There is significant concern over timeous response to a spill given the listed mitigations and rate of flow of the Agulhas current:

a) Blow Out Preventors are mentioned however capping stacks are not. Please include differences on both of these as well as the expected time for these to reach potential sites from shore from the location where they are stored. 

b) The Scoping Report makes no mention of mitigation or contingency plans in the event of a fire or explosions. The Chevron Nigeria Limited explosion of January 2012  and the Gunashli oilfield disaster of December 2015 are indicators of the dire need for proper mitigation planning. Please make these plans public.

No guidelines, plans or choices for dispersant use have been provided.

a) Please provide an explanation of their chemical components, toxicity, potential for bioaccumulation, ecological impacts through the water column and on the shoreline.

b) Please provide, in detail, their specific function, as well as proof of immediate availability of dispersants, considering this is of primary importance in effecting recovery rates.

8.LIABILITIES AND FINANCIAL RESPONSIBILITY FOR OIL SPILL REMEDIATION

The Scoping Report makes no mention of what appropriate insurance safeguards TotalEnergies have in place for remediation against oil spills and other environmental damages. Considering the serious toll a spill would have on safe recreation at beaches, healthy habitats for wildlife, industries such as tourism and fishing, the South African taxpayer and the general public, the EIA should produce proof of these insurance safeguards and a reasonable level of fiscal readiness for long term clean-up and reparation process, in the event of a major disaster.

a) Please indicate what insurance safeguards are in place in the event of accidental release.

9. EMERGENCY RESPONSE 

a)Please describe the protocol and time frame of response if there is accidental leakage/blowout from more than one well. 

b) Oil Spill Contingency Plan (OSCP) for Subsea and Surface Release, detailing Oil Spill Response, including the Blowout Management Protocol, Planning and Capacity, must be reported to both stakeholders and the public relevant for each exploration, extraction or decommissioning operation; must include the possibility of more than one event; and must be made available for proper stakeholder and I&AP engagement.

i. Any deficit of technological expertise / resources / difficulty of effective co-ordination with all government or conservation agencies that have a statutory responsibility for some aspect of offshore oil and gas activities regarding incident management, should be highlighted

c) The delegated National Incident Commander, along with the intended lines of responsibility for inter-agency efforts, should be made available for proper stakeholder and I&AP engagement. The citizens of South Africa need assurance that incident management is fully informed and has capacity to deal with the latest technology, practices and risks associated with, and due to, the different geological and ocean environments being explored, prior to commencement of drilling. 

d) The Scoping Report must provide an Assessment of Onshore Environment and Mitigation in case of oil pollution. Buried oil contaminants can resurface as the beach erodes. Buried oil must be removed through mechanical excavation. The Scoping Report needs detailed modelling of cross-shore distribution of oil contaminants relating to beach morphodynamic terminology to help optimize beach clean-up planning.

e) The ESIA must clarify a Dispersant Use Plan:

i. The most appropriate dispersants must be listed. An explanation of their chemical components, toxicity, and potential for bioaccumulation, ecological impacts through the water column and on the shoreline, and their specific function must be also provided. 

ii. There are many situations where the net environmental benefits of chemical dispersion are not clear. The dispersant effects to local flora and fauna must be indicated for all potential choices of dispersant in order for regulators to confidently decide on dispersant use issues.

iii. The ability to provide timely and scientifically sound outcome and effects information is essential to support the regulators in their decision-making role when approving the initial use of dispersants and whether to continue or cease their use during an incident.

A) Predictive migration / movement maps of dispersants based on sound oceanographic and metrological science must be provided.

B) Developers must provide proof of immediate availability of dispersants considering this is of primary importance in effecting recovery rates.

10. LACK OF ASSESSMENT OF ONSHORE ENVIRONMENT AND MITIGATION

In the case of a spill, buried oil contaminants can resurface as the beach erodes. Buried oil must be removed through mechanical excavation. 

a) Please provide detailed modelling of cross-shore distribution of oil contaminants relating to beach morphodynamic terminology to help optimize beach clean-up planning.

11. OPERATIONAL WASTE – TOXICITY, RADIOACTIVITY & POLLUTION

Global literature cites that discharges at similar depths may produce cuttings accumulations of up to 20m thickness within 100–500m of the well site and gradually get thinner away from the wellhead^[xiii].

a) Please ensure the Drill Cutting Discharge Modelling includes environmental effects and impacts, i.e. smothering. 

b) Please advise if drill cuttings’ offshore treatment and discharge to sea are assessed in terms of impact on seafloor/ benthic community, water column biology and expected dispersion?

Cognisance must be taken of the hazards of drill cuttings disposal onto the seabed (after cleaning) because they are often contaminated with drilling lubricants, synthetic-based drilling fluids (SBFs) and other non-aqueous drilling fluids (NAFs). 

c)Please outline what mitigation measures will be used against sediments contaminated with petroleum products, heavy metals and salts, which do not biodegrade and can accumulate in high concentrations affecting reproduction of marine life, and biomagnify toxic substances in the food chain.

d) Please provide a detailed report, describing the compound ingredients, levels of expected toxicity and radioactivity of the lubricants used, and their effects to species (including human), including larval stages.

e) Furthermore, please provide an explanation as to how these toxins will be mitigated during fish spawning periods where necessary.

f) How and where in the water column will drill cuttings discharge to sea be dispersed?

h) A detailed composition of these emissions and effluents regarding their toxicity, biodegradation, polynuclear aromatic hydrocarbon content and their metal content, need to be made public/ described in the ESIA.

i)What assurances are there that drill cuttings will be treated to reduce oil content before disposal over board? 

h) Will the NADFs be oil based or synthetic? Please describe their classification.

i) 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?

j) The Drilling Discharges Modelling Study must evaluate the contamination by not only 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 the tonnes of discharge from 10 wells. 

k) What is the period that the effects of the operational waste will have on the environment given the various types of waste, i.e. radioactive, and various detrimental chemicals and organics?

l) Please advise as to which actual licenced waste contractor will be used for disposing of volumes of NADF remaining from the project. It is in the public interest to know the name of the contractor should the option be employed.

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

n)Radioactive sources may be used for certain types of data acquisition. Please identify, and declare the half life/rate of radioactive decay, of the radioactive sources. 

o)Please identify the exact methods to be used for the treatment and also disposal of toxic radioactive drill wastes, frack flowback, drill mud, all radioactive substances and related tools, instruments used in the usage of any radioactive materials.

p)Please identify the exact methods for the treatment and disposal of the drill mud if onshore.

q)Please advise as to how and where toxic and also radioactive wastes are to be treated and disposed of, and in what municipalities?

s)How will compliance to international standards for the handling, storage, disposal etc. of radioactive substances be managed?

t)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?

u) Please give a realistic determination of the volume of gas to be flared per test, its emissions quantity and concentration, and expand estimates given that there may be up to ten wells in total. 

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

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

12. PIPELINE INFRASTRUCTURE 

Given the gas condensate will be transported to land via pipelines, both new and existing infrastructure, there is little information on impacts of the pipeline infrastructure specifically. 

a) Please provide comprehensive clarity of pipeline infrastructure and its environmental impacts and threats during and after the infrastructure has been installed. 

13. EXPLOSIVE USE 

The Scoping mentions that if required the use of explosives will be undertaken during drilling if required.

a) Please provide, in detail the use of explosives as well as who holds the permits in terms of use of explosives for these operations. 

b) Furthermore, what mitigation will be in place during explosions given the extremely high risk to marine fauna in the use of explosives. 

14. ENVIRONMENTAL BASELINE 

Despite the lengthy duration of an application process, at no time has TotalEnergies requested to undertake any Biological Baseline studies to satisfy the concerns raised by various stakeholders in the various application leading up to this application. There remains little information or knowledge of the deep offshore marine environment in the Areas of Interest, and therefore there is still no actual benthic data of what exploration drilling could potentially impact upon in terms of biodiversity. Remotely Operated Vehicle surveys to seek a suitable location for the pipelines and wellheads but these surveys simply cannot be deemed as a baseline survey (MPRDA Reg 49(1) (scoping) and Reg 50 (EIA)). 

15. SPECIES SPECIFIC MITIGATION 

Increased offshore anthropogenic activities, such as offshore mining, are likely to generate additional energy costs to migrating humpback whale populations^[xiv]. 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 concern that exploration will be occurring in their direct migration channels, thus disturbing and changing the behaviour of the population, at an unknown cost.  

Many of the species listed in South Africa are listed as Threatened (Vulnerable, Endangered and Critically Endangered) in SA waters. 

a)Please indicate which species are Southern African endemic species which occur within the area and at what depth ranges.

Furthermore, many species are listed on ToPS, CITES and CMS and therefore should be mitigated differently. 

a) Please comment on what biodiversity offsets are being considered and how the various levels of priority of threatened species will be determined and mitigated.

16. SEISMIC NOISE, PRESSURE EMISSIONS & SONAR SURVEYS

a) South Africa is a signatory to a resolution passed at the 67th International Whaling Commission (IWC) 2018 for the elimination of acoustic pollution that affects whales (of all 13 species and populations considered under the IWC), and therefore has a duty to cooperate. Please explain how South Africa can fulfil this duty given that this project may take up to 7 and half years to complete (TBC) and will create significant disturbance for an extended period for protected and unprotected species. 

i. The identified marine noise specialist must be capable and equipped to undertake in situ measurements (if they do not already exist) of the sound scape, and have the ability to interpret hearing thresholds (both Temporary Threshold Shift-based thresholds (TTS) and Permanent Threshold Shift (PTS)) of marine fauna in the proposed area. Rather than establishing the safety zone radius solely based on a fixed distance, the safety zone radius should be, at most conservative, of either 500 meters or a radius determined using propagation models based on the best available data and science for a pre-determined acoustic threshold (McQuinn and Carrier, 2005).

b)Please clarify whether the sonar surveys will take 4 weeks for the entire project (all 10 wells) or whether they’ll operate be 4 weeks per well?

c) Please include seabed coring in your noise modelling.

d)Please include Vertical Seismic Profiling in your noise modelling.

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

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

g) Please include the number and size of airguns being used.

h) Please establish cumulative acoustics limits for relevant species for the following:

i. Multi beam echo-sounder (70-100 kHz)
ii. Single beam echo-sounder (38-200 kHz)
iii. Sub-bottom profiler (2-16 kHz)
iv. Vertical Seismic Profiling (please confirm the relevant Hz range)
v. Sea bed coring
vi. Noise from the rig
vii. Noise from the many vessels operating simultaneously

i) Please indicate when these operations may run concurrently – seismic while drilling for eg., including across all wells.

j)Key findings and modelling must be projected for the full length of the proposed operation.

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

l)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.

m)Please indicate how precautionary protocols will be established in areas of steep bathymetry close to seismic surveys and multibeam bathymetric sonar. Ocean depth, multibeam echo sounders sweep a swath up to 7.4 times water depth and so affect a wide area. Potential impacts on marine mammals may range from physical damage, including gross damage to ears and the ‘bends’, temporary and permanent threshold shift (deafness), to perceptual (masking biologically significant noises) and behavioural impacts (temporary or permanent displacement and stress) as well as indirect effects (reduced prey availability) (Gordon et al., 1998). High intensity, low and mid-frequency sonar has been implicated in some fatal strandings (Frantiz, 1998).

n) Please indicate how precautionary protocols to limit the disruption of rest will be established for the extended period of this project. Perhaps one of the most overlooked aspects of anthropogenic noise impacts is the ‘disruption of rest periods’, which are important to migrating, or even generally moving, marine animals. Significant stress due to prolonged exposure to seismic and anthropogenic underwater noise has been measured in a number of species (Finneran et al., 2002; Eckert et al. 1998; McCauley et al. 2003; Rollard et al. 2012). These studies indicate cumulative effects could result in metabolic maladaptation, suppressing growth, immune system function, thermoregulation and the reduction of reproductive rates, with implications for individual and population fitness. Chronic problems of this kind are a legitimate conservation concern. 

o) Cumulative acoustic limits should be established, since there is a very real risk of displacement from feeding or breeding areas which could have far reaching effects not only for whole, and vulnerable, animal populations, but also on the fishing sector and our food security. 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.

p) Please 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).

The use of airguns in a marine environment requires mitigation and no seismic activities should take place during the known breeding and migration periods of cetaceans and turtles.

a) Please indicate how this will be mitigated.

Any operation of seismic surveys, vertical seismic surveys, Sonar surveys and bathymetric surveys happening concurrently must be taken into consideration with cumulative impacts assessed.

a) Please provide assessment of cumulative impacts.

17. LIGHT POLLUTION

Operations introduce considerable amounts of artificial light (e.g., electric lighting, gas flares) that can potentially affect ecological processes in the upper ocean, such as diel vertical migration of plankton. Artificial night-light also attracts numerous species, including squid, large predatory fishes, and birds. Please evaluate for mitigation the effect of lights and the physical presence of ships on the movement of sensitive species.

a)Please ensure a full assessment of light and mitigation thereof is undertaken.

18. INVASIVE SPECIES

Ships, drilling equipment and rigs are used and relocated all around the world. 

a) Please provide an assessment on the negative impacts on native biodiversity, including risk to fisheries, from invasive species colonising drilling infrastructure should be assessed and mitigated.

19. MARINE PROTECTED AREAS / CBAs 

The Scoping Report should propose buffer zones adjacent to Marine Protected Areas and Critical Biodiversity Areas in order to protect marine biota inside the designated areas to mitigate mining impacts in these areas.

The Scoping acknowledges that the pipeline transverses a significant portion of CBA natural and that oil and gas pipelines are not compatible with either CBA natural or CBA restore. 

a) Please ensure that the actual species and features which designate these areas as CBA’s are explained in detail. There is currently insufficient information to accurately assess impact of the pipeline.

b) A linear structure, such as a pipeline fragments habitats. Fragmentation needs to be explored appropriately. 

20. TIMING OF IMPACT 

Given the duration of the project (production and installation), impacts will be for approximately 20-30 years, throughout the year.

a) Please specify how species and ecological processes will be mitigated between seasons? In Particular for migration periods, spawning periods etc.

21. WELL ABANDONMENT

More information is required with regards to well abandonment and its mitigation. 

a) Will the wells be permanently or temporarily abandoned? 

b) Please describe the well integrity testing methodology to be utilised.

c) Please provide information on the types of well barriers utilised, types of plugging materials utilised, their functioning and verification. 

d) What does ‘monitoring’ entail, where will these data be housed, will South Africans have access to the data and what data would be embargoed, similar to the majority of data in this sector within South Africa? 

e)Well failure is a common enough issue[xv] and serious. Please advise as to which actual contractor will be used for well plugging.

f) 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:

• Storage of the well logging sourcesCalibration 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. 

g) Please identify control measures for each of these conditions.

h) How will TotalEnergies ensure monitoring will be carried out after production has ceased and throughout de-commissioning? Please provide a report on how the applicant will ensure well monitoring.

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

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^[i] Bonneuil, C., Choquet, P. L., & Franta, B. (2021). Early warnings and emerging accountability: Total’s responses to global warming, 1971–2021. Global Environmental Change, 71, 102386.

^[ii] Nara, H., Tanimoto, H., Tohjima, Y. et al. (2014). Emissions of methane from offshore oil and gas platforms in Southeast Asia. Sci Rep 4, 6503. https://doi.org/10.1038/srep06503

^[iii] Varon, D. J., Jervis, D., McKeever, J., Spence, I., Gains, D., and Jacob, D. J. (2021). High-frequency monitoring of anomalous methane point sources with multispectral Sentinel-2 satellite observations, Atmos. Meas. Tech., 14, 2771–2785, https://doi.org/10.5194/amt-14-2771-2021.

^[iv] Cusworth, D. H., Duren, R. M., Thorpe, A. K., Pandey, S., Maasakkers, J. D., Aben, I., … & Miller, C. E. (2021). Multi-satellite imaging of a gas well blowout enables quantification of total methane emissions. Geophysical Research Letters, 48(2), e2020GL090864.

^[v] IEA (2022). Methane Tracker. International Energy Agency, Paris, France. https://www.iea.org/reports/methane-tracker (accessed 21 Jan 2023). 

^[vi] Nisbet, E. G., Fisher, R. E., Lowry, D., France, J. L., Allen, G., Bakkaloglu, S., et al. (2020). Methane mitigation: methods to reduce emissions, on the path to the Paris agreement. Reviews of Geophysics, 58, e2019RG000675. https://doi.org/10.1029/2019RG000675 

^[vii] Frynas, J. G., & Buur, L. (2020). The presource curse in Africa: Economic and political effects of anticipating natural resource revenues. The Extractive Industries and Society, 7(4), 1257-1270.

^[viii] Gaventa , J. (2021) The Failure of ‘Gas For Development’ Mozambique Case Study. E3G. seehttps://www.e3g.org/publications/the-failure-of-gas-for-development-mozambique-case-study/

^[ix] Hanlon, J (2021) Could Mozambique become a hydrogen hub?.Mozambique news reports and clippings.https://www.open.ac.uk/technology/mozambique/sites/www.open.ac.uk.technology.mozambique/files/files/Mozambique_555-1July2021-Mphanda-Nkuwa-and-hydrogen_Special-report.pdf

^[x] Hosking, S., Du Preez, D., Kaczynsky, V., Hosking, J., Du Preez, M., Haines, R. 2014. The Economic Contribution Of The Ocean Sector In South Africa. Journal for Studies in Economics and Econometrics, 38 (2)

^[xi] Findlay, K. (2018). Review Of Ocean Economy Activities Within The South African Exclusive Economic Zone With Particular Reference To The Offshore Oil And Gas, Fishing And Mining Sectors. Oceans Economy, Cape Peninsula University of Technology, South Africa, p.20.

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