Oceans Not Oil, have set in motion critical debate around Eni and Sasol’s plans for exploratory oil and gas drilling off the KwaZulu-Natal coastline, raising a dozen issues they feel have not been adequately addressed by the draft Environmental Impact Assessment (EIA) report.
1) This EIA has not provided a sufficient evidentiary base to answer key questions around contributions to global warming and climate change by the proposed extraction of fossil fuels. An assessment of the potential end output of the project, i.e. the expected barrel delivery must be measured for its increase in carbon emissions to South Africa’s peak, plateau and decline commitments to the global economy.
2) All environmental impacts are assessed are limited to the duration of the project. These impacts should either be widened to include the effects of the projects ‘success’ e.g. greenhouse gas emissions, OR all impacts must be limited to duration, in which case the claims to contributing to RSA’s energy mix etc must be withdrawn from ‘The Significance of Impact for the No-Go Alternative’.
INCIDENCE MANAGEMENT
3) Further proof of insurance safeguards against incidence management and a reasonable level of fiscal readiness for long term cleanup and reparation process, in the event of a major disaster must be made public. This was requested of Sasol by ONO on 17th of May 2018.
4) Sasol claims the probability of an oil spill occurring being less than 1% in their Consolidated Response to the Durban Community Questions of May 2018. 1% is a very high percentage when the risk is our entire coastline. They must supply the criteria used to make this calculation, stating the exact calculated probability percentage, and the probability of a full-bore rupture in a given year for this assessment.
5) ENI stating that they have their own emergency team onboard is not sufficient response and the public needs to understand their full contingency plan. What f their team is incapacitated? Will they use dispersants or won’t they? etc.
6) The EIA’s Oil Spill modelling certainly doesn’t represent the typical behaviour of the Agulhas current. ENI must show the criteria of their modelling to justify the picture (figures 5-13 to 5-32 of the Oil Spill Report) which shows oil spill moving east , away from the coastline.
7) ERM must clarify why a reduced quantity of spill was used in the modelling compared with reported full well blow out quantities?
OPERATIONAL WASTE
6) EIA cites a ”Potential for short-term localised impacts on seafloor” and marine life, however research that shows that chronic intermittent exposure of species such as corals, shrimp, scallop, including larval stages of many species, to dilute concentrations of operational drilling wastes (characterized by tests as practically non-toxic) can affect growth, reproductive success and survival.
7) EIA shows the sediment layer at the wellhead itself being only 1m thickness getting thinner further away from the wellhead. The modelling also shows distribution effects of a 5 cm smothering layer of drill cutting sediment as close to 7 km2 in a month. The global literature cites that discharges at similar depths may produce cuttings accumulations of up to 20m thickness within 100–500m of the well site and gradually get thinner away from the wellhead . There is no projection for the full length of the drilling operation, which goes on for an average of 54 days. This model’s temporal selection of a month seems prevaricative without a substantiation.
8) Also the drill cutting modeling does not take into account further adverse effects on the wider marine environment from decommissioning and removal of the platform.
9) EIA claims that the effects of smothering are “Fully Reversible”. Given that smothering leads to mortality of deep water corals and that they are extremely slow growing organisms (hundreds of years old in many cases) they must support the claim.
VERTICAL SEISMIC PROFILING
10) This was listed as insignificant on the scoping report in small print on pg126 because it was “localised” and they would only produce a few “shots” for each well drilled. For this reason its given little significance in this EIA. ONO would like to raise this issue into full profile again because its harmful effects ( to cetaceans, fish, turtles,invertebrates, zooplankton) can be immediate, even if not ongoing.
AIR POLLUTION
11) If gas must be flared, an accurate determination of the volume of gas flared, its emissions quantity and concentration must be made made public.
12) Much baseline information remains unavailable, and considering that it is unclear whether conditions in the site remain unchanged or not is unclear because context has not been satisfactorily established ONO objects to the EIA and demands a proper Scoping Report done
