Do you care about the marine life off the Plett/Knysna coastline?
What is happening?
A company called Sungu-Sungu has been given a permit by the Petroleum Agency South Africa to do seismic surveys for gas and oil off our coastline. Quite apart from the eventual implications of any future drilling and exploitation, the seismic surveys themselves could severely affect the marine life off our shores, since their surveys are conducted with ship-based air guns that produce sound levels of about 280 decibels (in humans, sounds louder than 85 decibels can cause hearing loss).
What can I do?
You, the public, have until 15 June 2017 to comment and register your protest in terms of the Environmental Impact Report (EIA) that is taking place right now.
If you care about our marine life, take a few minutes to send in an email with comments to:
Wanda Marais: SRK Consulting
PO Box 21842, Port Elizabeth, 6000
Tel: +27 41 509 4800
Before 15 June.
Use the following subject heading in your email: 3D Seismic Survey in the Pletmos Basin, Southern Cape. SRK Project Number 510482.
What do I say?
We are making it easy for you as member of the public to make sensible comments on what is quite a technical issue. The background, tips on what to say and meaningful comments that can be made are set out below. This informational piece has been prepared for the Plett community on behalf of the Plettenberg Bay Community Environmental Forum by Polly Bramham, the Forum’s permanent consultant; Dr Gwenith Penry, a marine life expert; and Dr Mark Brown, director of the Nature’s Valley Trust.
Who can comment?
We encourage as many members of the public, organised groups, non-profit organisations, businesses and any other interested parties to submit comments to Wanda Marais at the address above. You do not need to be an expert to make meaningful comments.
This proposed seismic survey is part of Operation Phakisa, run by the Department of Environmental Affairs and designed to maximise the economic potential of our oceans.
The program is wide-ranging and covers improved tourism ventures, small-scale fishing cooperatives, increased protection of key areas through the proclamation of new marine protected areas, as well as exploring with a view to offshore mining. The seismic survey relates to the latter.
Almost the whole coast (except marine protected areas) is open for exploration by mining companies, who apply for permits to do so.
We want to outline the key issues that should be raised. We trust these will help you to submit comments that add weight to the opposition against this type of survey taking place off our Plett/Knysna coastline.
The letters of objection must be aimed at the actual 3D seismic surveying process, which forms the basis of this current Environmental Impact Assessment.
3D seismic surveys are conducted to acquire data on the subsea environment by using sound waves, and are used to understand the nature and extent of any oil and gas reserves in the area. The oil and gas industry uses this information to determine the economic viability of further exploration and development activities.
The current process is restricted to the seismic survey activities and does not embrace any drilling and production activities.
If deposits were to be found, and before drilling starts, the environmental consulting company working for Sungu-Sungu will have to submit a whole new Environmental Impact Assessment, and there will be further opportunities for public comment.
There are two issues we should all be commenting on:
1. Our opposition to the 3D seismic survey, and
2. ensuring that the mitigation measures proposed in the Environmental Impact Assessment report are adhered to if the survey does go ahead (equally important).
• While you may be strongly opposed to offshore drilling, oil rigs, and other activities and infrastructure associated with the exploration and possible production of oil and gas off our coastline, restrict your comments to the seismic survey, otherwise your comments will be considered inappropriate and be ignored. That is just the way the process works.
• Comments should focus on the seismic survey Environmental Impact Assessment. At least read the summary document provided by SRK Consulting if you have the time (see http://www.srk.co.za/en/za-sungu-sungu-pletmos-seismic-eia ).
• Lengthy submissions carry no more weight than short bullet point submissions, so don’t feel you have to write essays. Keep it simple, to the point and relevant, to ensure it is counted as a valid submission.
What to include in your comments
Your main comment should be that you oppose the seismic survey, and support the No Go alternative (which means “No survey”). Make the following comments to validate this:
• Disruptive seismic activity is in direct conflict with the ’sense of place’ that has been created for the marine environment of the Garden Route.
• The exploration zone falls within an area which is dependent on tourism and fishing, both of which are likely to be disrupted by the proposed work. Any impact on these activities should be avoided. A three-month period of disruption would severely impact our town.
• Seismic surveys so close to two Marine Protected Areas (Tsitsikamma and Robberg) conflict directly with the Department of Environmental Affairs’ own conservation priorities for this area.
• The area of the survey is directly alongside an international Marine Hope Spot with Mission Blue International (one of only six in Africa), which highlights Plett marine biodiversity as being of global significance for marine conservation.
• The surveys are close to an International Bird & Biodiversity Area, based on rigid global criteria used by Birdlife International to highlight globally significant areas for bird conservation.
• The high number of threatened, endangered or data deficient species present in the region requires further study before any high impact surveys such as seismic surveys are done. These species include the Bryde’s whale, humpback whale, southern right whale, killer whale, bottlenose dolphin, common dolphin, humpback dolphin, great white shark, blue shark, mako shark, African penguin, Cape cormorant, and Cape gannet.
• At present, we have no idea how the survey will affect local fish stocks, particularly bait fish stocks that support the food chain higher up.
Humpback whales are likely to occur in the exploration area. ©Gwen Penry.
What if it goes ahead despite our comments?
There is a chance that, despite our comments, the seismic survey may go ahead. If this does happen, we must make sure that the mitigation measures identified in the Environmental Impact Assessment report are implemented effectively in the survey to ensure minimum damage to the marine biodiversity in our region.
This is our only opportunity to influence how the survey is conducted, so unless we all comment on, and highlight the importance of the mitigation measures, they do not have to listen to what we say if it does go ahead.
Comments to be made on the seismic survey methods
• The proposed timing (February- May) coincides with the northward migration of small pelagic fish and the numerous predators that follow this migration (sharks, birds, predatory fish, dolphins, whales). This is exactly when these fish are off the coast between Knysna and Jeffrey’s Bay. We suggest the July-September period would represent less of a risk to the local biodiversity. By this time, most of the fish should be well north of the exploration area, humpback whale numbers should be relatively low and southern right whales will be inshore or further west. The Environmental Impact Assessment focuses on mitigation measures for migratory whales, but does not account properly for resident whales, such as Bryde’s whales, and migrating fish.
• We urge the authorities and the proponent to confirm and ensure that should the seismic surveys proceed, all mitigation measures will be adhered to, specifically regarding marine mammals. These mitigation measures have been detailed in the EIA report.
• We urge the authorities and the proponent to ensure that the Petroleum Agency South Africa implement all recommended mitigation measures as mandatory, and ensure strict compliance with these measures.
• All data collected by the onboard observers on seabirds, turtles, squid and marine mammals should be made available to researchers working in the area.
• Full disclosure and information on the company who will be conducting the survey and their Environmental Management Plan and contingency plans should be provided. This includes the total amount in Rands available to deal with disasters such as fuel spills, entanglement in seismic gear, and mass strandings of marine mammals.
• In the executive summary of the EIA report, page 5 Section 5.3, information is provided on Operational Emissions and Discharges. We have several concerns relating to the vague description of how waste will be handled. The wording in the last point states; ‘General and hazardous waste will generally be collected in waste skips …’
This is not satisfactory and we insist that ALL hazardous waste, sewerage and drainage or ballast water that contains contaminants MUST NOT be disposed of at sea. This is due to the proximity to two marine protected areas, for which such disposal could be catastrophic.
• The proponents and the company undertaking the seismic survey must notify Interested and Affected Parties (which will include YOU if you comment) of the start date of the survey so that research and monitoring of possible impacts can be conducted.
We trust you find this summary useful in compiling your comments. Remember to submit via email by 15th June – not to me, but to Wanda Marais of SRK Consulting, whose details were provided earlier on. Also, send this email to all your friends and ask them to comment as well.