Second Appeal Against Searcher
Herewith you’ll find ONO’s submission against the Environmental Authorisation for a proposed 3D seismic survey granted in terms of the National Environment Management Act, 1998 (No. 107 of 1998) (NEMA), as amended, and the Environmental Impact Assessment (EIA) Regulations 2014, as amended, to Searcher Geodata Uk Services Sas (Ref. 12/1/048). The proposed 3D survey would cover an area of up to 30 000 km2 in an area of interest located offshore from the Western Cape, 256 km offshore of St Helena Bay, extending north offshore of the Northern Cape coast over several petroleum licence blocks to 220 km offshore of Hondeklip Bay, between 1000m and 3500m deep:
….We refer to the provisions of the MPRDA and the provisions of the NEMA as amended, read with the provisions of PAJA and the Constitution, the latter of which enshrines the right to a healthy environment and, more importantly for the purposes of this appeal, provides for the right to administrative action that is lawful, reasonable and administratively fair.
We request that the decision to award the Environmental Authorisation (EA) to Searcher Geodata UK for a proposed 3D seismic survey (Ref. 12/1/048) be reconsidered and set aside and that all seismic survey operations be suspended, pending the finalisation of this appeal process and any further appeal or judicial review process. It is our contention that the award of the Environmental Authorisation is, inter alia, premature, regard being had to the followinggrounds of appeal:
- DECISION TO AUTHORISE MADE IN A CRITICAL POLICY VACUUM
1.1.The decision made by the Competent Authority fails to account for the requirement that the authorization of activities related to seismic survey operations for oil and gas must be carried out with due consideration for their compatibility with other marine uses and objectives within the broader marine environment. Specifically, the decision overlooks the absence of a comprehensive ocean governance framework, required to implement the Constitutional imperative flowing from Section 24 of the Constitution of the Republic of South Africa (1996). This has yet to be implemented.
1.1.1.the White Paper on the National Environmental Management of the Ocean (2014) has yet to be promulgated, and
1.1.2. The Marine Spatial Planning Act, 16 of 2018, (“MSPA”) still requires development of the Marine Area Plans (as defined in the MSPA).
1.1.2.1. This effectively renders the continuation of the environmental authorisation unlawful as it, inter alia, ignores alternate sectoral objectives as well as cumulative pressures to the marine ecosystem itself.
“Any right, permit, permission, license or any other authorisation issued in terms of any other law must be consistent with the approved marine area plans.” (Our emphasis added)
Therefore, the Competent Authority was never entitled, in law, to award an EA (ref. 12/1/048) to Searcher Geodata UK, granted on 21 October 2024, until such time as the Marine Area Plans are gazetted, come into law, and become binding. Because the Marine Area Plans have not yet been “approved” as envisaged by section 3(2) of the MSPA, no ‘right, permit, permission, license or any other authorisation’ (such as the environmental authorization) could be deemed to be ‘consistent’ with the said Marine Area Plans. Therefore, and considering the preemptory language used by the drafters of the MSPA viz the use of the word “must” – the environmental authorisation (i.e., the decisions that are subject to this appeal) granted to Searcher Geodata UK was unlawful and, as such, invalid.
1.2.The Competent Authority has failed to take into account the decision to implement Section 6 of the National Energy Act (NEA) into operation with effect from 1 April 2024, announced by President Ramaphosa. The National Energy Act, Section 6 requires the Minister of Mineral Resources and Energy to develop an Integrated Energy Plan (IEP) in the context of the current climate crisis. Without the legislative framework, this application lacks the appropriate guidelines for adopting and implementing performance management systems relating to global warming and international carbon commitments. Offshore exploration for fossil fuels lacks the legislative mandate to proceed whilst the IEP undergoes full public participation and consideration as per the Constitution.
2. FAILURE TO COMPLY WITH A MANDATORY AND MATERIAL PROCEDURE – PROMOTION OF ADMINISTRATIVE JUSTICE ACT, 2000 (ACT 3 OF 2000) SECTION 6 (2)(B)
2.1. The decision of the Competent Authority fails to meet the requisite procedural requirements as set out under the Mineral and Petroleum Resources Development Act (MPRDA). Specifically, Section 74(1)(a) to (c) of the MPRDA defines the “holder” of a reconnaissance permit or exploration right as the person to whom such right or permit has been granted, or that person’s successor in title. Further, Section 74(2)(b) establishes that a reconnaissance application must demonstrate that no other party holds a technical cooperation permit, exploration right, or production right for petroleum over any part of the area in question.
In the present case, Searcher is not the holder of the rights to Blocks 12/1/274 ER, 12/1/343 ER, and 12/1/339 ER. As such, Searcher is unlawfully holding and exercising rights over these blocks. The Competent Authority has failed to provide adequate legal justification for:
2.1.1.The Petroleum Agency SA (PASA)’s authority to accept Searcher’s application for seismic acquisition rights; and
2.1.2. How the authorizations granted comply with the procedural requirements of the MPRDA, particularly given that the rights are not lawfully held and thus contravene the provisions of the MPRDA.
Therefore, the Competent Authority’s decision is unlawful, as it has not been made per the requirements of the MPRDA.
2.2. The decision of the Competent Authority fails to properly consider South Africa’s international obligations under the Convention on the Conservation of Migratory Species of Wild Animals (CMS), to which South Africa has been a contracting party since 1 April 2002. Specifically, under Resolution 12.14 of the CMS, South Africa is required to conduct a comprehensive and rigorous Environmental Impact Assessment (EIA) prior to authorizing any noise-emitting activities that may harm marine life
In this case, however, the decision of the Competent Authority relies solely on an Environmental Management Plan (EMPr), rather than a comprehensive EIA. It is important to note that an EMPr is a distinct statutory instrument from an EIA and cannot be regarded as a substitute for a full and thorough EIA report. Consequently, PASA’s acceptance of the environmental report fails to meet the requirements set out by South Africa’s obligations under the CMS Agreement. This oversight constitutes a breach of South Africa’s duty to ensure the protection and conservation of migratory species and undermines the country’s commitment to international environmental standards.
2.3. The 3D survey area overlaps substantially with areas mapped as Critical Biodiversity Area 1 (CBA 1): Natural and Critical Biodiversity Area 2: (CBA 2) Natural. Approximately a third of the proposed 3D survey area is covered by CBA 1 and CBA 2. These CBA areas are no-go areas. However, the project map does not exclude them, plus this does not mean that these areas will not experience ensonification from the seismic blasting alongside them.
The decision to allow Searcher to conduct the survey abutting CBAs stands counter to the purpose of the CBAs, therefore failing to conform to the National Environmental Management Act principles of sustainable development and warrants review.
3. ENVIRONMENTAL MANAGEMENT PROGRAM REPORT NOT FIT FOR PURPOSE
3.1.If the primary objective of the Environmental Management Program Report (EMPr) process is to “give effect to precautionary measures” and support “ongoing proactive mitigation and the duty of care to the environment” (EMPr, p.2), then information critical to decision-making is largely missing from this EMPr.
3.2.The limited scope of the Environmental Management Program Report reflects a significant oversight that compromises informed, proactive, and precautionary decision-making. By failing to adequately address the direct connection between the project’s objective of facilitating further fossil fuel extraction and the severe, long-term consequences of this continued exploitation, it neglects the broader ‘poly-crisis’ of intensifying global warming, including the rising, irreversible acidity (Poloczanska et al., 2018), (Feely et al., 2009), (Zeebe & Wolf-Gladrow, 2001), and accelerated increased temperature of the oceans, the potential collapse of global ocean circulation system (Armstrong McKay et al., 2023), extreme weather events, and widespread species migration and extinction (Doney et al 2012), 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 (Pörtner et al 2022).
3.3. The report therefore does not equip the Competent Authority with a comprehensive understanding of the potentially irreversible and escalating environmental and social impacts of global warming, nor the associated legal consequences of continued operation. This omission undermines the obligation to apply the precautionary principle in safeguarding against future harm.
4. FAILURE TO CONSIDER REASONABLE APPREHENSION OF SIGNIFICANT HARM TO MARINE LIFE
4.1. The Acting Director-General (ADG) defines seismic surveys as “generally regarded as non-intrusive” in the key findings for his decision (p17). Yet the ADG finds it common cause that “the technology poses potential impacts on fisheries and marine fauna.”
4.2. A substantive obligation rests on the ADG, in the wholistic and precautionary interests of all living coastal species, as per the Integrated Coastal Management Act (N.E.M.:I.C.M.A.), to inform his decision to authorise. We argue the ADG did not apply his mind to the veracity of the evidence before him and say so for the following reasons:
4.2.1. Seismic surveys are listed activities (regulation 30 of the EIA amendments regulations of June 2021) under Section 24F National Environmental Management Act (NEMA) demanding mitigation according to South African law because their high-power penetrative shock wave properties propagate rapidly with a slow rate of dissipation (Stuhmiller et al., 1991; Phillips, 1986), occur every 10 /12 seconds, can be lethal or create injury and the onset of complications from brain, ear, eye, lung and abdominal organ damage can take place well after exposure. (Ketten, Lien, & Todd, 1993; Gordon et al., 2003; Weilgart, 2007; (Santulli et al., 1999); Popper & Hastings, 2009; Erbe & King, 2009; Garret, 2016)., intrude on the activities of a significant amount of species, affect the marine soundscape up to 4000kms away (Purdon 2018; (Hildebrand, 2005)) from the source, and can affect the internal organs, and so reproduction, of various species. Low-frequency energy from seismic sounds may travel long distances through bottom sediments, re-entering the water far from the source (Richardson et al. 1995; McCauley & Hughes 2006). The localised measurement of noise source to a point of reception is a massive understatement of the potential extent of noise impacts for oil and gas development. There is no way to minimise the traumatising sound or pressure generated from the seismic survey and no way to remedy their effects.
4.2.2. The extent of the survey covers 30 000km2
4.2.3.Airgun operations kill large quantities of plankton, vital to the marine food chain, up to 1.2 km from the sound source (Tollefson, 2017). McCauley et al., (2017)) study found zooplankton abundance dropped by two-thirds, suggesting significant depletion or disruption of plankton communities “is occurring on the scale of 3D seismic surveys undertaken”. This could have serious consequences for ocean ecosystems, as zooplankton are keystone species serving as larvae for commercially important fish. Without viable planktonic productivity healthy populations of fish, top predators and marine mammals are not possible.
4.2.4. Since October 2021, Cape fur seals (Arctocephalus pusillus pusillus) have been under duress, with die-offs of thousands of individuals. Their foraging areas include the continental shelf up to 120 nautical miles/222 kms offshore (Shaughnessy 1979) and therefore within the vicinity of the survey. Additional stress from seismic activity at this time is inadvisable (Harris, Olbers & Wright, 2022).
4.2.5. The duration of the survey is at least 9 months or at least 280 days. [there is a misleading understatement of duration: Firstly the duration fails to take into account the previous 4 months of seismic acquisition. Secondly it states,“The 3D survey will take in the order of 127 days including downtime and is proposed to be undertaken during the survey period (late December – May) but will likely commence in first quarter of 2025 and may extend into 2026.“].
This proposed schedule means the marine environment, which includes pristine Critical Biodiversity Areas, will experience 2419200 blasts of airguns at an average of 260dB per blast over and above the previous survey. This could justifiably be deemed incessant, cruel and unbearable for marine life which depends on sound to conduct their daily lives.
4.2.6. Vallarta’s NIA modelling is done for a 24-hour period, with 20 airguns, and assumes the airguns are stationary. This oversight undermines the report’s effectiveness in accurately assessing and mitigating the full scope of environmental risks. Vallarta has also chosen to model sites with upslope propagation that produce fast fading propagation, “whereas other signals may be detectable at ranges thousands of kilometers from the source when sound travels down the continental slope (McCauley et al., 2008; Duncan et al., 2013).”(Carroll et al., 2017) which means that his modelling is hardly “conservative” but rather an unrealistic best-case scenario.
4.2.7. The assurances of impacts being reversible are based on no data at all. Cognisance should have been taken of cascading effects of causing harm to one group inevitably causing harm to all groups, which could prove immensely and profoundly detrimental to the marine environment.
4.2.8. Hence there remains very real and unmitigated 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 fishing sectors and food security.
4.3. The results of EMPr should indicate a cause for concern for the critically endangered, endangered and vulnerable species and their migration paths as well as the critically endangered, endangered and vulnerable species habitats that will be subjected to the bombardment of this operation. All the above reasons warrant questioning the lack of a precautionary approach and the impact significance ratings given by this EMPr based on minimal biological baseline data.
4.4. Accepting that seismic surveys are a non-intrusive technology is both irrational and unreasonable. The idea that seismic surveys are non-intrusive has been tested in South African courts, and 2 judgments to date have applied a risk-averse and precautionary approach, which takes into account the limits of current knowledge about the consequences of decisions and actions and have terminated the seismic surveys (Bloem 2021; Thulare 2022).
We submit that the failure of the ADG to apply his mind to these relevant considerations as required by law, means that his decision to authorise the seismic survey is reviewable on the grounds specified in section 6(2)(c), and 6(2)(e)(iii) of PAJA.
5. FAILURE TO CONSIDER IMPACTS TO TANGIBLE AND INTANGIBLE HERITAGE
5.1. The Competent Authority has failed to meet its obligations to protect the rights of interested and affected communities (I&APs )protected under various international and domestic laws who are opposed to and have objected to this application (SIA. p.111) on the basis of their living cultural rights, heritage and spiritual well-being.
5.2. According to the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) which South Africa has ratified (2016), Indigenous peoples have the right to maintain and strengthen their distinctive spiritual relationship with their traditionally owned or otherwise occupied coastal seas (UN, 2007). The project could infringe upon these rights, leading to cultural erosion and loss of heritage
5.3. The poorly conceived SIA specialist report proposal to, “Re-assess post-project the potential effects on the identified communities and their intangible cultural heritage”(our emphasis) demonstrates a mindset of complete disregard for the rights of this heritage.
This recommendation is simplistic, reductive and grossly inconsistent with the degree of significance of, and makes a mockery of, the spiritual and cosmological value that the sea holds for coastal, fisher, Indigenous and First People communities. This poorly defined approach used by the heritage specialist does not address the objections raised by I&APs, limiting the ability of the Competent Authority to make informed decisions by making no distinction between quantitative and qualitative inputs.
5.4. The precautionary approach mandates maintaining the status quo unless there is sufficient information to realistically determine impacts. This project has served unjustly as a rationale for halting livelihoods in times of economic difficulty and impacting stakeholder marine-related intangible cultural heritage. The effects to their intangible heritage and relation to the sea remain, whether impacts occur close or far from shore.
5.5. The Competent Authority has not applied his mind to the dispossession which covers the loss of the incorporeal experienced by local communities. Concerns regarding impacts to intangible heritage were evident in both these recent cases, of which the ADG will be aware:
5.5.1. 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
5.5.2. Christian John Adams & Others v Minister of Mineral Resources and Energy & Others. (2022, March 1) Case No. 1306/22 in the High Court of South Africa Western Cape Division, Cape Town.
5.6. By failing to apply its mind to the objections and rights of Indigenous interested and affected parties the Competent Authority infringes their rights to intangible, ancestral and tangible marine heritage and has failed to uphold its responsibilities enshrined in the S15 of the Bill of Rights and international law.
6. CONTRADICTIONS
6.1. The ADG has not applied his mind to the temporal bias in information:
6.1.1. The lack of parity in time-frame application for the EMPr impacts assessments renders them unreliable. Environmental and social impacts are measured only during the reconnaissance operations, whereas the justification for the survey project impacts into the future beyond the project. This creates inconsistency for any rational comparison of effects and makes the significant ratings therefore irrational and skewed.
7. NO GO ALTERNATIVE NOT PROPERLY ASSESSED.
7.1. The ADG (Key finding 3.6) agrees that although no-go alternatives were identified, no in-depth assessments were carried out despite the fact that this impinges directly on the decision to either proceed with the project, or not to do so.
7.2. The ADG did not properly assess the alernative of no surveys based on international gas phase-out pressure; reduced funding, increased cost of capital, carbon tax, trade taxes, etc and that gas functions in the electricity sector are already outcompeted, or expected, based on trends(Halsey et al., 2022). There are strategic and economic reasons to re-evaluate identifying oil and gas resources to further exploration and production (International Institute for Sustainable Development, 2022).
7.3. The ADG did not apply his mind given the existential issues of lasting harm to the biodiversity and climate systems by the ongoing development of fossil fuels, which of necessity, require ongoing reconnaissance for the same. It is trite that the long-term benefits of eliminating GHG emission generation should be considered via the No Go option. As previously stated (point 3.2.), the link between this project, whose sole purpose is reconnaissance for the expansion, and sustained use, of fossil fuels, and these existential threats, has not been made with the effect of producing a comprehensive ‘no-go’ option. On this basis alone the authorisation should be reconsidered and set aside.
7.4. The ADG has failed to consider the three court cases related to offshore oil and gas to date, taking the ministers (DMRE and DFFE) and developers to court to demand the minister engage the ‘No-Go’ option to stop development before it starts. The applicants represent a large number of communities and organisation and they span South Africa’s coastline (North East, East and West Coasts):
7.4.1.South Durban Community Environmental Alliance et al. V Minister of Environment, Forestry and Fisheries & Others, (2021, June 14) Case No. 29433/21 in the High Court of South Africa Gauteng Division, Pretoria; https://drive.google.com/file/d/12loY5RLGd0CGRoMrc2pn7kt4yohkCWxS/view
4.4.2. Sustaining the Wild Coast NPC and Others vs. Minister of Mineral Resources and Energy and Others.(2021, December 28) Case No. 3491/2021 in the High Court of South Africa Eastern Cape Division, Makhanda/Grahamstown. https://cer.org.za/wp-content/uploads/2021/12/SWC-v-Shell-Wild-Coast-Seismic-Blasting-Interdict-28.12.2021.pdf
7.4.3. Christian John Adams & Others v Minister of Mineral Resources and Energy & Others. (2022, March 1) Case No. 1306/22 in the High Court of South Africa Western Cape Division, Cape Town. https://cer.org.za/wp-content/uploads/2022/03/Adams-and-Others-v-Minister-of-Mineral-Resources-and-Energy-and-Others-ZAWCHC-24.pdf
7.5. If the purpose of the 1623 project is in establishing the location of gas reserves and producing exploratory wells once found, the No-Go alternative should have included greater consideration of renewable energy alternatives to generate energy and provide energy feedstocks for industrial applications.
7.6. The EMPr has inadequately considered the no-go option in that it has only dealt with the potentially negative economic impacts thereof. This is a biased and one-sided approach, particularly when the no-go alternative will ensure no pollution, no catastrophic spill, no climate impact, no impact on fisheries, no socio-economic impact, no increased violent conflict and militarization, no human rights abuses and no harm to the marine environment associated with offshore oil and gas exploitation.
7.7. Oceans Not Oil respectfully submits that the EMPr is inherently flawed and that the Minister contravened section 6(2)(e)(iii) of PAJA by failing adequately to consider the “no-go” option.
8. FAILURE TO ASSESS REPEATED, PERSISTENT OR CUMULATIVE EXPOSURE IMPACTS TO SPECIES
8.1. The Competent Authority has failed to consider repeated, persistent or cumulative exposure impacts to species, knowing that the Orange Basin has become a “hot-spot” area for the oil and gas and other mining sectors, including beyond South African borders.
8.2.The EMPr understates the compounding abiotic and biotic stressors associated with the frequency and enormous extent of the multi-client 3D surveys and exploration planned for 2025 and onwards. (Parsons et al., 2009)warn that some of the more insidious and potentially devastating impacts arise through long-term, repeated, persistent or cumulative exposures. The risks associated with compounded behavioural disturbance and how chronically-present sound could constitute a threat to populations by changing behaviour and distribution regularly at critical times and in critical areas.
8.2.1. The reversal of noise was demonstrated in 2020, while 60% of the globe was in lockdown and a 20% reduction in ocean noise, the response was also almost instantaneous, where large marine animals began coming closer to shore and claiming back their ancestral territory (Duarte et al, 2021).
8.3. Stress in marine mammals related to anthropogenic noise exposure has been conclusively proven (Wright et al., 2007). Neither stress nor maladaptive neuroplastic changes within the central auditory pathway symptomatic of noise exposure induced tinnitus in marine animals are broached.
Significant stress due to prolonged exposure to seismic and anthropogenic underwater noise has been measured in a number of species (Finneran et al., 2002)(McCauley et al., 2003); (Rolland 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. The ADG has not taken into account the chronic problems of this kind of stress which are legitimate, but have been disregarded as a conservation concern in this Authorisation.
9. FAILURE TO ADEQUATELY ASSESS THE NEED AND DESIRABILITY OF THE PROJECT
9.1. The Competent Authority has failed to justify the necessity of this project in light of the substantial risk of exacerbating social tensions highlighted in the original SIA. The needs and desirability of this project appear unduly influenced by vested interests, such as Sasol, without due consideration of the broader social implications. The Authority has not adequately addressed or mitigated the potential negative consequences nor provided a clear, evidence-based rationale for proceeding with the project despite the significant risks of societal unrest.
9.2. Since the projected benefits of this project are to be conflated with the anticipated outcomes of eventual gas production, because the renewable sector could rely on the less intrusive multibeam bathymetry instead ,it is incumbent upon the Competent Authority to also critically assess the associated harms arising from its exploitation:
9.2.1. South Africa has international commitments to the United Nations Framework Convention on Climate Change (UNFCCC) 1997, the Kyoto Protocol 2002, the Paris Agreement on Climate Change 2016, Global Biodiversity Framework adopted at COP15 in Montreal 2022, that are incompatible with the long term purpose of this reconnaissance activity.
9.2.2. The Competent Authority has failed to adequately interrogate the assertion that the identified gas will serve as a “transition fuel for the country up to 2030” (BAR p. 35). Given that the survey is expected to conclude by 2026, the Authority must be fully aware of the extended timeframes required for offshore exploration and production. At present, Total’s Brulpadda exploration right is the only one advancing toward a production right (D.F.F.E, 2023). The assertion that gas will be available for commercial production before 2030 is based on a flawed assumption, which undermines the legitimacy of the project’s need and desirability.
9.2.3. This flawed assumption poses a substantial risk of inconsistency with South Africa’s binding carbon budget and the peak-plateau-decline emissions trajectory, potentially delaying the nation’s transition to Net Zero beyond the 2050 target and is, therefore, liable to further review.
9.3. The Competent Authority has failed to adequately to assess unequivocal scientific conclusions regarding the effects of oil and gas production on global warming:
9.3.1.Developing new oil and gas fields is ‘incompatible’ with limiting temperature rises to 1.5°C, as evident in the IPCC’s 2022 report (Pörtner et al 2022), resolute that global oil and gas production and consumption must decrease by 29% by 2030 and that new oil and gas development and exploration must end immediately. These findings are supported by the IEA’s Net-Zero by 2050 report, which states that emissions from oil and gas must decline by 65% by 2050.
9.3.2. The Competent Authority has failed to critically assess the economic viability of the discovered gas in relation to its competitiveness within the energy market. Affordable gas is not secure(Halsey et al., 2022).
9.3.2.1. Nor has Competent Authority interrogated how the gas will facilitate the projected shift from the current growth rate of 1.6% in 2023 to a projected rate of between 6% and 8% (BAR p. 36), despite the absence of the necessary infrastructure, conversion of gas turbine power stations and a functioning gas market to support such a transformation. This lack of analysis undermines the robustness of the claims made in the BAR and constitutes a failure to fully evaluate the feasibility of the proposed project.
9.3.3. The Competent Authority has failed to carefully interrogate the claims that” gas will assist in reducing the emissions of greenhouse gases (by reducing the country’s reliance on coal for electricity generation” (BAR p.35).
9.3.3.1.Recent findings on the extent of methane leakage from gas infrastructure undermine claims of environmental benefits over other fossil fuels. A Natural Resources Defense Council (NRDC) study (Swanson et al., 2020) 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 ship it, it ultimately presents a significant threat to the climate. The Competent Authority has accepted assumptions of well-run that have yet to be converted, a national gas infrastructure that has yet to be built, and does not assess greenhouse gas emissions or health impacts that would arise from developing a gas economy.
9.3.3.2. 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 from the coal sector.
9.3.3.3. Methane is a significant greenhouse gas, driving climate change. It is only a low-carbon fuel at ignition. It is the primary contributor to the formation of ground-level ozone, a hazardous air pollutant and greenhouse gas, exposure to which causes 1 million premature deaths globally every year[1]. Over a 20-year period, it is 80 times more potent at warming than carbon dioxide.
For all the reasons stated above, it is our submission that the appeal should succeed and that the proposed exploration must not be permitted to proceed.
We look forward to your response.
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