Source photo by IOL iol. co. za
GUIDELINE FOR PUBLIC PARTICIPATION SOUTH AFRICAN OCEAN ESPLORATION AND DRILLING
RE: OCEAN EXPLORATION AND DRILLING OFF THE EAST COAST OF SOUTH AFRICA, WITHIN BLOCK ER 236, AS PROPOSED BY THE ITALIAN PETROLEUM COMPANY ENI https://dc.sourceafrica.net/documents/118506-Eni-Final-Scoping-Report-08march2018.html
Source photo by IOL iol. co. za
The deadline to participate to the Public consultation is the 8th of November, please write your comments to:
Environmental Impact Assessment (EIA) eni.offshore.eia@erm.com
cc: SASOL sasol.italy@it.sasol.com
Italian Minister Environment segretariatogenerale@miniambiente.it
SA Acting Minister EnvAffairs Heibre.Roos@dst.gov.za
CITES Italy (for the Coelacanths fish) dpn-cites@minambiente.it
The South African Institute for Aquatic Biodiversity a.paterson@saiab.ac.za
What you need to know before writing your comments:
South Africa Synthetic Oil and Liquid (SASOL) and Ente Nazionale Idrocarburi (ENI, Italy) are set to explore off the coast of KwaZulu-Natal South Africa for oil and gas. This entails drilling, putting at risk the unique marine life and healthy oceanic ecosystem of South Africa, which includes 37 species of whales and dolphins, but also turtles, endangered sea birds and prehistoric species of fish, i.e. the living fossil, Coelacanth.
Source photo by Wikipedia Common
ENI is hoping to locate massive oil and gas reserves under the seabed at depths of between 3800m and 4800m in front of Durban, in a 400 km long exploration block, known as Block ER 236. The project includes to drill wells from late 2019, early 2020.
Oil and gas reserves are hidden deep under the sea floor in cavities in the bedrock. Geologists hired by mining conglomerates can use various methods to locate these deposits and one of these methods is seismic surveying which involves directing high powered airwaves towards the sea floor. The air-guns are towed behind ships and shoot loud blast of compressed air through the water and kilometres into the seabed, which reflects back information about buried oil and gas deposits. The blasts are set at 10 second intervals and the sound waves can travel over 4000km and can be ongoing for up to 24 hours a day, months at a time. Seismic surveys have been proven to be a cause of marine life massive destruction.
KwaZulu-Natal, the coastal region target of this project, is renowned for its famous and beautiful beaches. However, healthy oceans are critically important to marine life and to coastal communities whose economies rely on tourism, fishing and recreational activities. Opening up new offshore areas to drilling risks permanent damage to ocean and beaches without reducing our dependence on oil.
Photo credit by Jon Hrusa
KZN’s coast could be subject to huge oil spills equivalent to the BP oil spill in the Gulf of Mexico in 2010, with calamitous long-term costs for the tourism and fishing industries.
Public Participation is an important part of legislation in South Africa, please take part. Find below a detailed sample letter.
GUIDELINE
To:
Environmental Impact Assessment (EIA)
Ms Charlene Jefferies
2nd Floor Great Westerford
240 Main Road
Rondebosch
7700 Cape Town
South Africa
+27 21 6815400
+27 21 6815400
cc: SASOL sasol.italy@it.sasol.com
Italian Minister Environment segretariatogenerale@miniambiente.it
SVI-UDG@miniambiente.it
SA Acting Minister EnvAffairs Heibre.Roos@dst.gov.za
CITES Italy (for the Coelacanths fish)dpn-cites@minambiente.it
The South African Institute for Aquatic Biodiversity a.paterson@saiab.ac.za
5 November 2018
Re: OCEAN EXPLORATION AND DRILLING OFF THE EAST COAST OF SOUTH AFRICA, WITHIN BLOCK ER 236, AS PROPOSED BY THE ITALIAN PETROLEUM COMPANY ENI https://dc.sourceafrica.net/documents/118506-Eni-Final-Scoping-Report-08march2018.html
Dear Ms. Jefferies,
Referring to ENI’s proposal, we want to raise our concerns, in particular:
1. Wildlife:
- Heritage and prehistoric fish species are going be to put at risk. The Coelacanth dates back 420 million years, grow up to 2 metres in length and adults can weigh up to 80 kilograms. Coelacanths are classified as Critically Endangered on the Red List of the International Union for Conservation of Nature, and are also officially protected from being traded internationally according to the Convention on International Trade in Endangered Species (CITES). However, these protections would not be enough to save them in the event of an oil spill. There are just 30 exemplars and is one of the rarest fish in the world. Only a very small colony is known to exist off the east coast of South Africa in underwater canyons near South Africa’s Sodwana Bay, adjacent to the iSimangaliso wetland park and world heritage site. The Sodwana Coelacanths are about 40 km from the northern boundary of the ENI exploration area and nearly 200 km north of the first drilling sites. Air-blasting and drilling into the seafloor as part of oil exploration produce intense vibrations and sound waves which have been proven by multiple studies and researches to have a catastrophic impact on marine life. South Africa currently has a network of 23 Marine Protected Areas which will be inevitably put at risk and hugely affected by this project.
- Each year Southern Right whales migrate from East Africa waters into the coastal waters of the Western Cape to calve and nurse their young. The animals, often mere metres from the shore, provide unsurpassed whale watching opportunities between June and November. Humpbacks migrate through the region between May and December each year, while Bryde’s whales are found slightly further offshore all year round.
- The Whale Route starts from Durban (KZN, South Africa) and extends to the south of Cape Town, along 1,600 plus kilometres of whale watching coastline. The route traverses several famous protected areas. At least 37 species of whales and dolphins can be found in the waters off South Africa.
- Many species of Turtles, Cape Fur Seals, African Penguins and Black Oystercatcher birds are among the most famous marine species populating the South African coasts.
2. The Environment
- Offshore drilling will potentially produce petroleum along with a host of other environmentally harmful substances including arsenic, nickel, copper, chromium, zinc and barium.
- Heavy metals and hydrocarbons can be devastating for the health of marine organisms and to the people who live and feed off the coast. Another major environmental concern is linked to the disposal of highly toxic production waste caused by the hydrocarbon drilling. Small oil leaks usually occur during the production and transport of crude oil and pollutes the waters surrounding the rig.
- Discharges from drilling consist mainly of crushed material from the borehole (cuttings) and chemicals used during the operation. The literature on the discharge of drill cuttings and associated drilling fluids indicate that it will cause the death of the benthic (bottom-living) organisms living in and on sediments covered by cuttings in the immediate vicinity of the discharge point.
- We therefore would demand that a full survey of such bottom living organism is established prior to the drilling process and that this is monitored as to its state of health.
3. We support the prevention and avoidance of negative impacts
- We would like the Ecological Importance Sensitivity (EIS) to prevent and avoid negative impacts rather than listing assessments of risks and proposing the monitoring of these negative impacts. The blasts are supposed to be repeated every 10 seconds. The sound waves travel for over 4000 km, not allowing any wildlife to escape; in South African waters they can injury 138.000 whales and dolphins and disturb or kill million more organisms. Monitoring is not enough.
- The most common impacts on wildlife are the decline in sea birds populations, the destruction of fish eggs and larvae, the immune system suppression in organisms, the destruction of delicate seabed, the temporary or permanent hearing loss in fish and mammals, the abandonment of habitat, the disruption of mating and feeding, disorientation, beach stranding and death. For whales and dolphins, who rely on their hearing to find food, communicate and reproduce, being able to hear is a life or death matter. These blasts have shown to cause massive mortality and destruction in zooplankton, which is the base of all marine food chains. Resulting in increased economic challenges.
- Very worryingly, the East Current is the highway for fish and mammal species travelling down the Eastern seaboard of South Africa to the nutrient-rich and breeding grounds of the Agulhas Bank. Anything that occurs off KwaZulu-Natal’s coastline will end up being swept to the Agulhas since this is the inevitable nature of the current. In addition, it is suspected that the south-flowing Agulhas current is of critical importance to the spawning patterns of many fish species that move northwards inshore up our coastline with larval formations carried south by the current.
4. The Report is missing crucial information on social and health impacts on communities and people
- Oil spills can quickly traverse vast distances. These types of devastation will also destroy livelihoods to over 50 000 subsistence fisher folk who eke out a living daily. Even small occasional spills will impact local communities and increase poverty and lead to more people joining the unemployment line.
- Desalination has been prospected as a solution to severe droughts regularly occurring in South Africa and affecting not only wildlife and worldwide famous National Parks but millions of people. Once again, the quality of coastal sea-water must be utterly and continuously protected.
- With regards to the health of the communities who rely on a healthy oceanic system to eke out their living, the following has been found: itchy eyes, watery eyes, nosebleeds, wheezing, sneezing, and coughing are all symptoms of exposure to crude oil. Chest pain, respiratory problems, dizziness, gastrointestinal problems also common ailments. A study of clean-up workers from the 2002 Prestige oil spill in Spain found increased DNA damage, especially among those who worked along beaches. Such genetic changes can sometimes lead to cancer. Mental health increases in symptoms of post-traumatic stress, generalized anxiety disorder and of depression.
5. The Report is not taking sufficiently in account the safety and rescue standards of South Africa
- Precedent international disasters have shown how oil spills spread far and swiftly. The drilling operation will rely on the rescue of traditional South African rescue services. South Africa simply does not have any capability or capacity to provide long distance rescue effort and certainly not in the weather conditions likely to precipitate a disaster. For example, South Africa does not have an existing offshore rescue craft capable of providing a rapid response. The National Sea Rescue Institute (NSRI) is strictly inshore and the naval capability is virtually non-existent. Furthermore, it is not the navy’s role to provide standby services for private institutions and companies like ENI. In addition, aerial support also requires specialist aircraft that South Africa simply does not possess.
- The odds therefore that a plant upset could become a runaway uncontrolled event impacting on both life and the environment are significantly greater than the norm of rigs in the 1st World North Sea or Gulf of Mexico where, as we know, enormous ecological harm has been wreaked by this industry despite the proximity of state of the art rescue and repair facilities.
- The prospect of a catastrophic spill and the near impossibility of introducing a successful capping of the blow out at the depths cited are of huge concern.
- We require significant detail to be presented in this aspect given the learnings of the Deep Water Horizon disaster.
6. Political consideration
- The protected areas are only 0.4% of the oceans around South Africa which is far from the target of 10% to be met by 2020 as South Africa has committed to as a Member of the UN. In 2014 the president of South Africa announced that 5% protection would be achieved by 2016 and 10% by 2020, through the establishment of an expanded network of Marine Protected Areas (MPAs) Accordingly, in February 2016 the Minister of Environmental Affairs published the intention to declare a representative network of 21 new, expanded Marine Protected Areas and invited the public and key stakeholders to comment. These areas were identified as important to support fisheries recovery and productivity, to protect fragile and sensitive habitats and endangered species, to help combat climate change, and to ensure resilient and healthy oceans that can support coastal communities and a sustainable blue economy into the future. Unfortunately, over four years later stakeholders have had no feedback from the Department of Environment Affairs about when the MPAs will be declared.
- There have also been concerns raised that the delay may be linked to the fact that by 2014 the Petroleum Agency of South Africa had already leased about 95% of our oceans to large companies for oil and gas exploration.
- South Africa’s Government has not even started investing in green energy yet. On the contrary, it carries on allowing the expansion of coal mining and fossil fuels investments. Many countries of the third world are far more advanced than South Africa in this sense. The Government should finally put green investments in its agenda and stop allowing these kind of explorations.
- In addition and very worryingly, it has been reported that Chinese vessels are allowed to overfish in South African waters and that they regularly abandon industrial fishnets, once damaged, in the water; this has been reported to severely affect marine life as well as single-use plastic still heavily used at any industrial level in South Africa.
- Sewerage outfalls of big cities like Cape Town are already pouring an average of 40 million litres of untreated sewage per day, with their chemical content, straight into the ocean from the submerged outfall pipes located normally within 2 km offshore. In this context of marine environmental dis-attention, drilling oil near or upstream protected areas full of genuine and untouched ecosystems should be avoided and unmistakably forbidden.
7. Conclusion
- The protection of African communities and people, their health and wellness is for us of crucial importance.
- The protection of the pre-historic Coelacanths species and of so many other iconic marine species, are for us of crucial importance.
- A catastrophic oil spill pollutes tens of thousands of kilometres in a very short space of time as the oil is carried by currents. Methods used to reduce the severity of an oil spill, such as chemical dispersants, are also known to have detrimental environmental impacts, persisting in the environment for years after a spill. The Gulf of Mexico oil spill can be made an example of how offshore oil and gas drilling causes detrimental effects to the ecosystem.
- We are under the impression that all tiers of Government are promoting the idea of allowing these activities to go ahead without proper and meaningful consultation with the public communities. This type of reaction from Government is contradictory because whilst they are promoting tourism with the main focus on the Sardine shoals, whales and dolphin sighting points, beautiful marine nurseries, various bird life and small B&BS which thrive on our beautiful beaches and ocean, they are destroying or allowing the destruction of this beautiful ocean we have. It seems that the offshore oil and gas project will only benefit the elite and rich people of society whereby once again the poor gets dealt a raw deal.
- This project seems to not even offer any employment or benefit opportunity for South Africans.
- Considering the high risk of pollution and disaster in one of the strongest currents in the world, plus the scant employment opportunities that the offshore oil and gas industry offers South Africans, the market, legislative and governance uncertainties and lack of public participation within this sector, and the economic importance of our fisheries, leisure and tourism industries dependent on functional healthy oceans, we must question the logic of extracting a fuel that produces further climate change and ocean acidification acceleration.
WE STRONGLY OPPOSE THE APPROVAL OF THIS PROJECT
Photo credit by Algoa FM
8. Links
1.Protected Species and Areas: The Coelacanths
https://www.int-res.com/articles/meps/161/m161p001.pdf
https://www.jstor.org/stable/24859008
https://www.nationalgeographic.com/animals/fish/group/coelacanths/
http://www.photodestination.co.za/marine-protected-areas-in-south-africa.html
https://showme.co.za/secunda/lifestyle/threatened-fish-in-sa-waters/
https://www.aquarium.co.za/blog/entry/marine-protected-areas
https://www.westerncape.gov.za/general-publication/protecting-our-marine-life-0
https://www.aquarium.co.za/blog/entry/sassi-red-listed-fish-species-of-the-two-oceans-aquarium
https://www.saiia.org.za/wp-content/uploads/2018/07/saia_spb_176_-harris-Lombard_20180711.pdf
https://www.saambr.org.za/marine-protected-areas-mpas/
https://www.saambr.org.za/wp-content/uploads/2018/10/Fact-Sheet-3-MPA.pdf
https://www.marineprotectedareas.org.za/
https://www.pressreader.com/south-africa/sunday-tribune/20180415/281758449875052
https://www.sanbi.org/media/south-africa-announces-new-marine-protected-area-network/
https://rovingreporters.co.za/south-africas-oceans-get-much-needed-protection/
https://saiia.org.za/wp-content/uploads/2018/08/saia_spi_58_purdon_20180620.pdf
https://rovingreporters.co.za/eni-linked-to-dark-deals-in-africa/
https://www.researchgate.net/publication/314202665_Oil_gas_and_renewable_energy_Western_Indian_Ocean
https://www.boem.gov/ESPIS/3/3268.pdf
2. Impacts
https://www.aquarium.co.za/blog/entry/The-plastic-problem-How-much-plastic-pollution-is-in-our-ocean
https://www.environment.co.za/mining/mining-sucking-south-africa-dry-poor-governance.html
https://www.environment.co.za/mining/acid-mine-drainage-cost-gold.html
https://www.environment.co.za/mining/effects-of-mining.html
https://www.environment.co.za/mining/call-mines-invest-african-health-systems.html
https://www.environment.co.za/mining/south-african-mine-pollution.html
https://www.environment.co.za/mining/mining-industry-to-benefit-from-ndp-gordhan.html
https://www.environment.co.za/recycling
https://weather.com/science/nature/news/penguins-south-africa-oil-spill/
https://www.news24.com/SouthAfrica/News/several-penguins-treated-after-pe-oilspill-20160819
https://www.environment.co.za/mining/deep-sea-mining-insanity-greed.html
https://www.environment.co.za/mining/battles-over-uranium-coal-and-gold-mining.html
https://www.iol.co.za/capeargus/news/drilling-threat-to-marine-organisms-16704608
3. Desalination
4. Chinese Vessels overfishing in South African Waters
5. Public Comments and Objections
https://becomingvisible.africa/2018/10/17/filmmaker-janet-solomon-objects-to-eni-sasol-eia-oct-2018/
http://www.facing-finance.org/files/2018/05/DP6_ONLINEXVERSION.pdf