On 13 December 2022, The Green Connection and Natural Justice made a joint submission on the draft environmental impact assessment (EIA) report for Karpowership SA’s proposed gas to power project in Saldanha Bay.
The eco-justice organisations argue that the environmental authorisation to be refused, highlighting several flawed assessments of marine and socio-economic impacts – largely a result of incomplete information – particularly regarding underwater noise.
Karpowerships’ application for environmental authorisation was initially refused by the Department of Forestry, Fisheries & Environment (DFFE) on a number of grounds, including that the EIA did not comply with the public consultation and information gathering requirements stipulated in the National Environmental Management Act (NEMA), and did not undertake the required underwater noise modelling study was not done. A new EIA process was commenced after Karpowerships’ appeals against the refusal decisions were dismissed, and the matter was remitted back to DFFE so that various gaps in information and procedural defects relating to the public participation process could be addressed and the matter reconsidered.
The Green Connection’s Community Outreach Coordinator Neville van Rooy says regarding the new EIA process, “Since there are still many gaps and limitations in the specialist studies included, it raises concerns about the adequacy of the assessments and the validity of the EIA report findings. How can it be claimed, as it is in some instances, that there is “no impact” when the real potential impacts could not be properly evaluated? There are too many discrepancies to determine the true potential consequences for the environment and the people who depend on it. Therefore, environmental authorisation should be denied.”
On 13 December 2022, small-scale fishers and community members from West Coast towns held a peaceful demonstration, with plans to hand over a list of grievances to the environmental assessment practitioners for Karpowerships, Triplo4. However, while the agreement was that someone would meet the fishers to take their comments, they were advised grievances cannot be accepted, only comments and that a fisher representative would be engaged later.
Small-scale fisher from the West Coast Solene Smith says, “We want to voice our feelings about these Karpowerships. For too long we have struggled and pleaded with the government to stop with all oil and gas exploration and related activities in our waters. But no-one listens to us, and these companies keep coming back, again and again, with our government always seeming eager to give them permits. It is so unfair when you consider how long we, as small-scale fishers, must wait for permits to allow us to fish and feed our families.”
“We don’t need politicians to talk on our behalf because they do not speak with indigenous small-scale fishers, who know these waters best. These companies and the government need to start respecting us, our culture, customary rights and livelihoods. We have been fishing in these waters for generations. Why must we struggle in the land of our birth? Government, everyone, please hear our plea.”
On 14 December 2022, The Green Connection submitted comments on the TotalEnergies EP South Africa B.B. (TEEPSA) Deep Western Orange Basin (DWOB) Draft Scoping Report (DSR) in respect of its application for environmental authorisation to undertake exploration well drilling off the West Coast of South Africa. TEEPSA proposes to drill up to ten exploration wells which could last for approximately 9 months per well, and also plans to undertake sonar surveys.
The Green Connection’s comments raise queries relating to the assumptions and parameters to be used in the oil spill modelling (OSM) that will be undertaken in the impact assessment phase of the EIA, most of which were not disclosed in the DSR. Given that the DSR acknowledges that the greatest potential risk of offshore oil and gas exploration activities is the impact of a major oil spill (for example as a result of a wellhead blowout), The Green Connection believes that it is important that the OSM models the worst-case scenario as best practice.
In addition to modelling the fate and trajectory of a major oil spill, the OSM is intended to inform other specialist studies to be undertaken in the impact assessment phase. The results of the OSM will thus influence the significance of predicted impacts of a major oil spill on the marine ecosystem, marine fauna (such as snoek, whales and turtles), the shoreline, as well as socio-economic, cultural and heritage impacts on (amongst others) small-scale fishers and communities that depend on fishing for their livelihoods. The Green Connection also raises concerns relating to the need and desirability of more offshore oil and gas exploration from a climate change and right to food perspective.
According to van Rooy, “As we see climate change get worse, how can we still look for more fossil fuels? Oil and gas both emit carbon dioxide when burnt and should no longer be seen as a desirable energy option. And according to reports from the International Energy Agency the world already has enough – from current reserves and from those projects already approved – which means we do not need to look for more, as we transition to sustainable renewable energy sources.”
“The oil spill in Mossel Bay, which has been polluting and harming the ocean and beaches, for weeks now, is another cause for concern.. While the origin of the spill remains unknown, we question whether this could be coming from a plugged oil well. As an organisation that wants to protect our environment and oceans for future generations, The Green Connection believes that we must proceed with caution, when considering offshore oil and gas. The culture and heritage of many South Africans are tied to the coast, the ocean and fishing. Indigenous small-scale fishers rely on the ocean to feed their families and make a living, while local tourism operators rely on a healthy environment overall, to entice tourists to feed into the local economy,” adds van Rooy.