Time for action for a coast under seismic assault – with concerning environmental risks but questionable returns considering the cost of future extraction at depth and in rough seas. Environmental and community activists lost the court interdict they brought against Shell to stop Shell’s Seismic Survey off the wild coast of South Africa.  That may not be the end of the struggle by local communities to stop an assault on our sea life. Neither is it the end of new applications for additional sections of the South African coast.  Under  current consideration is an application by CGG Services SAS a French based survey company for seismic surveys off the South African Coast between Quebega (Port Elizabeth) and Plettenberg Bay. SLR consultants have produced an Environmental Management Plan to support the application for a new 5 month Seismic Survey, planned to start in January 2021.  The complex EMP is quite a mission for concerned citizens to wade through.  Nonetheless, the description of the extent in time and area of the Seismic Survey makes it clear, even to lay people, that it is an action of assault on the environmental commons without public benefit.   I am strongly opposed to the  Seismic Survey (SS) for gas and or oil off South Africa for the following reasons:

Firstly, I believe that the actual impacts on marine life are not sufficiently well established. It is arrogance to assume that we fully understand the complex marine ecosystem functioning at the depths and distance out to sea that will be impacted by the  Seismic Survey. Our marine ecosystem is already under pressure from overfishing, toxic chemical pollution, Climate Change impacts on sea temperature, currents and weather etc. As a result, `traditional’ movement patterns of migratory species is shifting outside of previously predictable seasons.  We don’t know fully what the tipping points are – but SSs are likely to add to existing environmental stresses.

In addition, the Seismic Survey impact areas overlap with fishing grounds, with MPAs, EBSAs and CBAs as well as with a region identified by the 2018 National Biodiversity Assessment as vulnerable. While fish catches are diminishing, fishing is still an NB source of economic activity and protein to coastal communities. There are so many factors that come together for the breeding success of migratory species such as chokka, pilchard and anchovies, etc. We are unlikely to be able to prove that a bad recruitment year is a consequence of the SS. Because of this the precautionary principle of no to the SS application should be applied.  Protected area such as MPAs are not walled sanctuaries where the inhabitants are protected from human impacts. Their purpose is to retain marine wilderness areas where the marine web of life is not disturbed. However the area being applied for the SS completely surrounds the offshore Port Elizabeth Corals MPA.

The results of the survey will be private data while the environmental impacts will be an externalisation of the ecological costs – known and predictable as well as unknown and unpredictable – onto the marine commons. To quote: “As seismic surveys do not have any specific guaranteed impacts that would need to be rehabilitated, no financial guarantees are required in terms of the Financial Provision Regulations” (to rehabilitate environmental impacts).   Nice for the Surveyor CGG services SAS – but what about the impacted sea creatures?  This is not acceptable – most especially given the Renewable Energy (RE) alternatives to costly and risky deep sea gas and or oil exploration and extraction.  If the purpose of the SS is only to sell off data about potential reserves to inflate share prices of interested companies, then the interference with the marine environment is ethically even less acceptable.

Secondly, the Need and Desirability section is heavily weighted by outdated policies in support of Fossil Fuel. Even the more recent, but already out of date, IRP of 2019 capped allocations for renewable energy. This has contributed significantly to our critical energy crisis. We don’t lack renewable energy opportunities. Instead decisions around our energy future remain captured by vested fossil fuel interests.

No natural gas is not a green energy source. The EMP makes a number of valid references to continued exploitation of Fossil Fuels being in direct contradiction with other national policies around Climate Change and Environmental Protection. Environmental Protection, not for elites to enjoy, but to ensure that our biodiversity and ecosystems are sufficiently intact to provide the necessary resilience to Climate Change impacts for ALL.  Our economy, as an emerging nation with high unemployment, has to move off fossil fuel at a pace that supports a Just Energy Transition. Costly and environmentally risky deep sea gas off our rough coastline is not an affordable energy option.  Already South Africans are seriously beleaguered by the cost of electricity.

We already import gas from Mozambique and have an opportunity through the Southern African Power Pool (SAPP) to focus attention on co-operating with Mozambique to generate gas powered electricity and support the regional grid.

In terms of general economic well-being and the strategic importance of energy, there are numerous studies which show that Renewables provide more jobs than gas generated electrical power. And, certainly more of the range of jobs that South Africans will qualify for.

Specific comments and questions of clarity are as follows:   

1 The Task Force on Climate-related Financial Disclosures. FINAL-2017-TCFD-Report.pdf (bbhub.io) Is calling for transparency around funding and ownership of enterprises that contribute to GHG emissions and Climate change. This leads me to ask:

Who will own the SS data? Who is partnering with the foreign survey company CGG Services SAS. CGG is not an extraction company and neither do they own the `mineral licenses’?  Which financial institutions are providing the speculative funding / loans?  In view of the history of energy decision-making in South Africa (during and post-Apartheid) being linked with vested interests, it is essential that the public is given information about the companies involved in exploration for energy reserves. The sea belongs to all and so there should be full disclosure of the involved interests.

2 Seismic Surveys for gas off South Africa – assault without return! Deep sea gas is no longer the cheaper energy option!

2.1 The IRP and NERSA are bound to look at least cost options when approving new energy generation.  Ball-park costing of the price of offshore gas for electricity would make a valuable contribution to a true Need and Desirability exercise. Instead, the report quotes from a range of government energy and economic policies to promote the Seismic Survey application. As stated above, these governmental policies, while still in place, are out of date. The reduced costs of RE, as well as the large employment benefits no longer makes deep sea gas and / or oil an affordable alternative. Given the expertise on the SLR EMP team and CGG experience in the exploration field, ball park costing of the price of offshore gas for electricity would be a valuable comparison against the current costs of RE.

2.2 The EMP statement that: “the no-go alternative would thus mean that other sources of energy would need to be identified and developed in order to meet the growing demand in South Africais true. Yes, alternatives in the form of RE and battery and other storage have been identified. They would be much faster to develop, than off shore oil / gas but are being blocked by artificial caps on RE.

2.3 In its 2021 Energy Transition Index, the World Economic forum ranked South Africa at position 110 out of 115 countries around the world – 5th from the bottom in its  performance and readiness to transition to RE. Energy Transition Index Report 2021 | World Economic Forum (weforum.org).  This has bearing on the EMP statement that:  “the proposed exploration has no direct influence on South Africa’s reliance on hydrocarbons and whether consumers use more or less oil or gas, nor on which types of fossil fuels contribute to the countries’ energy mix.Actually, the proposed exploration perpetuates the mindset of fossil fuel as the energy of choice and contributes to attitudes against a transition to clean energy.

3 Biological impacts.  The detail explaining the different fisheries and different levels of marine protected areas in and abutting the SS area is highly relevant. I have already made a number of comments regarding the difficulty of assessing the impacts on the marine ecosystem above.  Two references which dispute that the impacts of Seismic Surveys can be adequately mitigated and are not significant are:

PROPOSED SEISMIC SURVEYS OFF THE WILD COAST – SOME FACTS – SAAMBR 

By Dr Judy Mann of SA Association  of Marine Biological Research

Also an in depth study by D a v i d  R u s s e l l, F i s h e r i e s C o n s u l t a n c y ,  W i n d h o e k , f o r  t h e R e s p o n s i b l e  F i s h e r i e s  A l l i a n c e.  His report is a PDF Assessing the Impact of Seismic Surveys on South African Fisheries (rfalliance.org.za)

It includes disturbing information on the potential links between Seismic Surveys impacting the hearing of Cetaceans and being a plausible factor in strandings.  He also highlights the heightened impact of cumulative seismic surveys overlapping in time.   If you have not read this research, I trust that you will use it to update the EMP.

As well as the need for a sense of respect and sanctity for marine life in protected areas in and abutting the area of interest for the SSs, I have the following further concerns:

3.1 What is the potential combined impact of the Shell Seismic Survey on Wild Coast as the timing will potentially overlap with CGG survey. The combined seismic survey noise interference and disturbance to marine life results in such a large area being impacted. This is likely to have specific relevance to migratory species of cetaceans, fish and larval plankton.  Sound is a physical shock wave and a vast number of marine species are especially sound sensitive.  The EMP speaks about: “cumulative impacts may be likely and there would need to be alignment in planning of such concurrent operations in order to avoid cumulative impacts.“  However, I did not see any details of how this cumulative disturbance would be managed/ mitigated?

3.2 I did not see any information regarding the potential impact on sharks. Apart from being keystone species on which the ecosystem stability depends, Great white sharks are a protected species in south Africa.

3.3 The preferred start date for the SS is January lasting for 5 months. IF the application is approved, what are the implications of a potential delay?  By June both the whale and sardine migrations could start? Given the increasing unpredictability of seasons, thanks to GHGs and Climate Change induced chaos in the weather, the SS could overlap with increases in vulnerable species in the area.  Will the SS then be stopped?

3.4 This leads to the question of who will be the Lorax on the survey ship? Who will speak up for marine wildlife and make sure that if there are higher than expected sightings, the SS will be stopped? Also, to make sure the survey vessel does not drift into the MPAs nor encroach on the fishing grounds at the wrong time of year?

3.5 A Grievance mechanism is a nice idea – but if there is a valid grievance then damage has already been done!

4 The EMP ranks Employment and Business Opportunities resulting from CGG’s Reconnaissance Application as negligible positive.

Weighed against the environmental risks of a SS and then the (highly likely) prohibitive costs and risks of actual deep sea extraction, the Seismic Survey Reconnaissance Application should not be supported. 

In Conclusion:

1 The environmental Precautionary Principle needs to be applied and the Seismic Survey application should be rejected on the basis that it overlaps with vulnerable and protected marine habitats. Mitigation measures to protect species provide little guarantees at that depth and distance out to sea.

2 The current application will not result in any significant economic benefits to the South African Public.

3 Prospecting for natural gas off shore sends the signal that South Africa is not committed to a Just energy transition to RE. The resulting FF finds, if there are any, are not likely to be more affordable that RE and they will come with significant environmental risks.

4  As the sea is part of our global and national commonage, the public are entitled to know who and which companies are funding the SS and who will hold the data. This is a policy of the Climate Change Task Team on transparency around ongoing investments into Fossil Fuel exploration and extraction.

Kim Kruyshaar for GAIA – Every day is Earth day. Let us live this!

03 December 2021