Why are we compromising Critical Biodiversity Areas for Oil + Gas?
ONO submits comments on Block3B/4B Draft Scoping and Environmental Impact Assessment (DESIA) (Ref Number: 1570) for proposed exploration well drilling by Africa Oil Sa Corp (AOSAC), Ricocure (Pty) Ltd and Azinam Limited Block off the West Coast of South Africa
This letter serves to lodge an objection by the Oceans Not Oil coalition to the proposed exploratory drilling of up to 5 wells in Block 3B/4B off the West Coast of South Africa, which covers an area of approximately 17 851 km2 and is situated between latitudes 31°S and 33°S on the continental shelf in water depths ranging from 200 m to 2 000 m. Block 3B/4B is located approximately 120 km west of St Helena Bay and approximately 145 km south-west of Hondeklip Bay off the West Coast of South Africa.
Whilst we appreciate the opportunity to comment on the Draft Africa Oil Sa Corp (AOSAC), Ricocure (Pty) Ltd and Azinam Limited (the applicants) Scoping on the Environmental and Social Impact Assessment (DESIA) and proposed public participation process for the proposed offshore exploration and environmental authorisation application for Block 3B/4B, let it be said that we are greatly concerned by the ‘development footprint’ of the proposed 5 appraisal wells, sonar and vertical seismic profiling, drilling, its wastes and cumulative impactful operations in and adjacent to critical biodiversity regions and marine protected areas.
The objection is based on the following, inter alia:
- NEED AND DESIRABILITY
The need and desirability of the Project have not been conclusively nor consistently established, as required by regulation 18 of the EIA Regulations read with regulation 23(3) and Appendix 3 to the EIA Regulations, since impacts and benefits of the project need to be assessed using the same parameters and criteria.
The seriousness of global warming is grossly understated in the DESIA and its existential risks should feature in the need and desirability section of the draft to present the DMR as decision maker with an accurate, fair and reasonable risk assessment framework on which to assess environmental authorisation. - ALTERNATIVES UNCONSIDERED
The actual alternative to extraction of fossil fuels is an investigation into the use of renewable energy, which should have been detailed according to NEMA Regulation 982 (2014). Please provide energy-supply alternatives to this project that will not carry the externalised costs of global warming and climate change to the degree that the project’s flaring and methane leakage will. These externalised costs from the fossil fuel industry to the climate emergency are well understood, meaning this project will knowingly contribute further to global temperature rise.
This DESIAR’s reluctance to engage sharp reductions in the production and use of all fossil fuels is, therefore, tantamount to unlawful endangerment, since their extraction and consumption can be avoided, cannot be reversed and will cause irreplaceable loss.
3. CUMULATIVE IMPACTS
a. The DESIAR of the project, as required by the NEMA EIA Regulations, including the cumulative climate impacts of the project.
The DESIAR has failed to adequately assess and consider the full extent of cumulative impacts of the exploration, or future production activities, on fisherfolk or marine ecosystems. There is no evidence that climate change impacts have been at all considered in respects of increased risks to the drilling structures, and in turn, of increased environmental impacts. In failing to do so, the EIAR fails to give effect to section 63(1)(g) of NEM: ICMA, which requires the competent authority to consider the likely impact of coastal environmental processes on a proposed activity.
b. Increased offshore anthropogenic activities, such as offshore mining, are likely to generate additional energy costs to migrating humpback whale populations[i]. 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 species, at an unknown cost.
4. TIMING
a. Please clarify the total anticipated time for this project, as there are distinct variances between the different reports of operations taking between 90 days per well to 120 days per well.
b. Is it correct to assume the wells will be not managed concurrently?
c. It is not enough to say that “the applicant’s strategy for future drilling is that drilling could be undertaken throughout the year (i.e. not limited to a specific seasonal window period)”. These exploration activities are highly invasive in terms of waste cuttings, sediment plumes and noise pollution to those below the sea surface whose lives are lived according to seasonal breeding, feeding and migrations, with a high risk of displacement from these routes for turtles, resident and migrating cetaceans, seabird populations and fish species.
d. The proposed operation window needs to be defined by the EAP. Timing of this exploratory drilling is critical for least possible impact. Best practice to mitigate negative impacts of oil exploration on endangered marine life is to separate them in time, space, or both.
e. Based on 2.a. and an understanding that bathymetric multibeam sonar acquisition Vertical Seismic Profiling surveys are man-made sonic phenomena that are actively pursued for their powerful effective qualities, and that existing guidelines do not offer adequate protection 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 deep-diving species, such as beaked whales ; limitations in monitoring requirements; lack of baseline data; and other biological and acoustic complications or unknowns, please justify why the use of sonar will “not be limited to a specific time of the year”[p.9].
f. Based on 2.a. please justify why the model parameters of the drilling discharge scenario are set at a 50-day total which appears a significant understatement of risk calculation, especially considering the proximity of Critical Biodiversity Areas to the well sites. How, for instance, should the decision maker assess impacts of smothering and range of water column impacts if discharges take place for more than twice 50 days per well?
5. DISCHARGES
“The risk is short term in the water column, because of the natural dispersion and dilution induced by the currents.” [p.30 Drilling Discharge Modelling Technical Report]
- Please justify mitigation by dilution when bentonite is practically insoluble in water and in aqueous solutions, swelling to form a colloidal solution.
- Please confirm that maximum drilling fluid discharged wastes, based on 4 months for 5 wells, for this project could amount to:
Riserless 131m3 x 5 cuttings = 655m3 of smothering cuttings
374t = 1449 litres drill fluids x 374 x 5 = 2 709 630 litres
Risered 275m3 x 5 cuttings = 1.375km3 of smothering cuttings
444t = 1449 litres drill fluidsx 444 x 5 = 3 216 780 litres
High Viscous Gel sweeps / KCl Polymer PAD mud: 200bbl = 159 litres drill fluids x 200 x 5 = 159 000 litres
BOP Hydraulic fluid: 1000l x 4 x 5 = 2 000 litres
Totalling 6 105 410 litres or the equivalent of 3256 Olympic sized swimming pools of drill fluids and 2.03km3 of cuttings
6. SOCIO ECONOMIC ENVIRONMENT
a. The DESIA has failed to make clear that this project has the potential to reduce catch rates for large pelagic longline fisheries and small-scale fishers for well over a year, which 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. The significance of impact of both cumulative effects and extended duration should be considered extremely high should any displacement or accidental discharges occur.
b. and their constitutional rights of fishers must be accommodated by transparent, convincing, accounting utilising up-to-date data for compensation for loss of income to fisheries and subsidiary businesses.
c. These figures should be independently audited and must include economic losses by disruptions, loss of earnings plus the effects of negative publicity, persisting public perceptions and potential fishing and harvest bans.
d. Please support your view in detail, how “coordinating exploration activities and fishing/logistics operations coupled with strategies for job retention and skills development can mitigate these negative effects”.
e. Please define “short term disruption “given this project could last a minimum of 2 years.
f. Have all West Coast fisheries and small-scale fishers been informed as to the potential full duration of this project?
7. BIOLOGICAL OCEANOGRAPHY / MARINE PROTECTED AREAS AND OTHER CONSERVATION AREAS
Since “petroleum production is classified as “not compatible” in CBAs (Harris et.al. 2022)” and that the AOI is in close proximity to the Child’s Bank and Benguela Muds Marine Protected Areas, overlapping with some Critical Biodiversity Areas (CBA), the DESIA understates the project’s direct area of influence.
- A full evaluation of each of these CBAs and MPA/ ESA and their sensitivities are expected to be fleshed out in the ESIA.
b. In addition, the buffer areas surrounding these areas are expected to be noted and added to the operational plan.
c. Considering that the AOI is surrounded on all sides Critical Biodiversity Areas (CBAs) alternatives to release of drill cuttings overboard must be reassessed.
d. The environmental assessment process is used to understand the potential environmental impacts of a development. This project will produce intense man-made noise pollution, produce carcinogenic, radioactive and polluting wastes in the water column and on the sea bed, over an extensive area possibly for years, next to critical biodiversity areas.
e.It is also evident that this Area of Interest was clipped out during the spatial planning processes when the CBA’s were created by SANBI. This highlights the complete disregard for marine biodiversity and conservation in South Africa when oil majors and DMRE has intent for an area.
8. TOXICITY, RADIOACTIVITY & POLLUTION
a. The DESIA mentions three main additives used during the drilling process: retarders, fluid loss control agents and friction reducers, and that these additives are polymers generally made of organic material and are considered non-toxic.
i. 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.
ii.Please provide a detailed report of their effects to species (including human), as well as larval stages.
iii. Please indicate any compounds for which there is incomplete information on their chemistry and health hazards.
b. What assurances are there that drill cuttings will be treated to reduce oil content before disposal overboard?
c. Will the NADFs be oil based or synthetic? Please describe their classification.
d. 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. Please confirm this method is being considered. How will the transport of these cuttings to shore take place?
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 in the public interest to know the name of the contractor should the option be employed.
f. 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.
g. Please advise as to which actual licenced waste contractor will be used for disposing of hazardous wastes from the project, for the same reasons as above.
9. ATMOSPHERIC EMISSIONS
a. Have the applicants endorsed the Zero Routine Flaring by 2030 initiative launched by the World Bank and the United Nations in 2015 for new field development, and if so what consequence does this hold for this operation?
b.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 five wells in total.
c. What carbon budget has been allocated by the Minister of Forestry, Fisheries and the Environment for this project?
d. Has a greenhouse gas mitigation plan been prepared and submitted to the Minister for approval?
10. WELL ABANDONMENT
a. Well failure is a common enough issue[ii] and serious. Please advise as to which actual contractor will be used for well plugging.
b.Will the well abandonment be permanent or temporary?
c. Please provide information on the types of well barriers utilised, types of plugging materials utilised, their functioning and verification.
d.Please describe the well-integrity testing methodology to be utilised.
e. Incidents involving radiation sources in well logging have occurred mainly as a result of operator error or equipment failure. According to the International Atomic Energy Agency 2020 Radiation Safety In Well Logging: Specific Safety Guide report, the hazards involved and the necessary control measures should be identified for each of the following conditions:
i.Storage of the well logging sources;
ii. Calibration and operation of the well logging tools;
iii.Transport of the sources;
iv.Work at the site with the well logging tools;
v. Maintenance of the tools;
vi.Disposal of disused sources; and
vii.The possibility of theft and sabotage of radioactive sources.
Please identify control measures for each of these conditions.
f. Please provide a report on how the applicant will ensure well monitoring to identify bubbling/leaking events will be carried out after drilling/ /logging/ production/ de-commissioning has ceased.
11. NOISE EMISSIONS
a. Cumulative impacts must be established for single and multibeam. Bathymetric sonars, VSP, well logging, well testing, equipment in the water, machinery noise, propeller cavitation as well as the drilling .
b. Please include the number and size of airguns being used.
c. 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 coringNoise from the rig
vi.Noise from the many vessels operating simultaneously
vii.Dynamic Positioning Systems from all vessels, including support vessels.
d. Please indicate when these operations may run concurrently, such as VSP while drilling, and across wells or individually?
e. Key findings and modelling must be projected for the full length of the proposed operation
f. What international operational guidelines will be followed for mitigation of noise during this operation?
g. 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.
h. 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).
i. 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.
j.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.
k. 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).
12. EMERGENCY RESPONSE
a. Please describe the protocol and time frame of response if there are 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.
c. 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
d. 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 the commencement of drilling.
e. The DESIA 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 DEIAR needs detailed modelling of cross-shore distribution of oil contaminants relating to beach morphodynamic terminology to help optimize beach clean-up planning.
f. 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 on 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.
- Predictive migration / movement maps of dispersants based on sound oceanographic and metrological science must be provided.
For all the reasons stated above, it is our urgent request that the proposed exploration does not proceed.We look forward to your most urgent response.
[i] Braithwaite, J.E., Meeuwig, J.J., Hipsey, M.R. (2015). Optimal migration energetics of humpback whales and the implications of disturbance. Conservation Physiology 3: doi:10.1093/conphys/cov001.
[ii] Vignes, Birgit, and Bernt S. Aadnoy. “Well-Integrity Issues Offshore Norway.” Paper presented at the IADC/SPE Drilling Conference, Orlando, Florida, USA, March 2008.
Oceans Not Oil 