Tuesday 27 March 2018

Comments from SDCEA on offshore oil and gas exploration drilling within block ER2369 of the east coast of KZN


Sasol and Eni are set to explore the coast of KZN with offshore oil and gas drilling. KZN 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 our oceans and beaches without reducing our dependence on oil. 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, yet this process has been flawed on the consultant’s part. The coastal community of KZN has been undermined and this not acceptable.

Impact on the communities, people and environment

When oil spills occur they can bring catastrophic harm to marine life and devastating losses for local businesses. Even routine exploration and drilling activities bring harm to many marine species. Expanded offshore drilling poses the risk of oil spills ruining our beaches, bringing harm to those who live, work and vacation along the coasts, as well as harming habitats critical to plants and animal species. Oil spills can quickly traverse vast distances. Exploration of oil and gas presents multiple forms of environmental degradation. These developments and projects will not only cause catastrophic destruction with the above-mentioned impacts but will also destroy livelihoods to over 50 000 subsistence fisher folk who eke out a living daily. When seismic tests are conducted, they clearly have an impact on marine life. The fish are either killed or forced to leave the area. This impact will increase poverty and lead to more people joining unemployment line.

Emissions to air

The oil and gas industry is a significant source of greenhouse gas emissions as well as toxic volatile organic compounds (VOCs). VOC in combination with NOx contribute to the formation of ground-level ozone and is a known causal agent of acid rain. The atmospheric pollution will have measurable impacts on the surrounding ocean but also become potentially entrapped in air masses moving towards the coastline where it will be deposited as acid rain. The drilling of wells and production process require vast amounts of energy usually provided by the burning of gas and diesel. The impact of this activity needs to be accurately assessed in terms of tons of fuel burnt and hydrocarbons released. Assuming that oil or gas is discovered then this would no doubt need to be flared off until such time as it can be capped and processed. During this time vast quantities of particulate matter and volatile organic compounds will be released into the atmosphere, indeed continuing throughout the production process. In addition the associated fugitive emissions from retrieved product is an additional source of toxic pollutants as the venting from either onsite (barge/tanker) or onshore (storage tanks and pipeline valves) must be evaluated. The carbon generated from flaring will also add to the existing problem and create added negative consequences in terms of climate change.

South African Coastline

Our coastline is recognized as being one of the most hostile and formidable to shipping. Large freak waves, storms and the presence of a year round strong (4 knot) north-south current all spell trouble for any stationery vessel anchored in place. The impact of the dynamic Agulhas current and its vital role in important biological processes must be evaluated. The positioning of the rig is fairly and squarely within this current that is in effect 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 KZN coastline will end up being swept to the Agulhas such is the inevitable nature of the current. It will not simply disperse over the vastness of the ocean as you are effectively discharging hazardous waste into a fast flowing offshore river. 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. Allowing the presence of ecologically destructive drilling and oil/gas extraction is foolhardy and flies in the face of the precautionary principle.

Health, safety and rescue considerations

In this context consider that the drilling operation lies beyond the rescue envelope 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 we have no exiting offshore rescue craft capable of providing a rapid response. The NSRI is strictly inshore and the naval capability virtually non-existent. Furthermore, it is not the navy’s role to provide standby services for private institutions. In addition aerial support also requires specialist aircraft that South Africa simply does not possess. The key limitations are restrictions placed on aviation flying over water meaning that specialist aircraft would be required. Where and what are these and who will fund them? Where will they be based? Would they really be able to respond in time in order to assist in event of ecological or human calamity? Consider what occurred on Piper Alpha…and there you had state of the art first world facilities whereas in South Africa things are significantly more third world. The odds therefore that a plant upset could become a runaway uncontrolled event impacting on both life and the environment are therefore 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.

Impacts of Drilling

Discharges from drilling consist mainly of crushed material from the borehole (cuttings) and chemicals used during the operation. In addition brought to the surface is “produced water” that will contain trace elements of oil assuming oily condensate is discovered. This requires evaluation. With regard to the drill cuttings it is not known what alternatives are proposed or whether the cheapest option of discharge into the nearby ocean is the only option being considered. For example is it not possible to injecting everything back into suitable geological formations or take it to shore for further treatment. More drilling muds and fluids are discharged into the ocean during exploratory drilling than in developmental drilling because exploratory wells are generally deeper consequently this is a very real threat to the environment.
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 benthic biota is established prior to the drilling process and that this be monitored as to its state of health. It is also known that offshore rigs can dump tons of drilling fluid, metal cuttings, including toxic metals, such as lead chromium and mercury, as well as carcinogens, such as benzene, into the ocean all of which must be assessed.
The prospect of a catastrophic spills and blowouts is a documented threat from offshore drilling operations and the near impossibility of introducing a successful capping of the blowout at the depths cited are of deep concern to us. We require significant detail to be presented on this aspect given the learnings of the Deep Water Horizon disaster.

The iSimangaliso Wetland Park

The iSimangaliso Wetland Park is South Africa's very first World Heritage site since 1999 (Unesco), it is also the third largest protected area in South Africa. Nelson Mandela stated that “iSimangaliso must be the only place on the globe where the oldest land mammal (the rhinoceros) and the world's biggest terrestrial mammal (the elephant) share an ecosystem with the world's oldest fish (the coelacanth) and the world's biggest marine mammal (the whale)”.

The consultants are prone to making wild and unsubstantiated and absolutely unverifiable claims. Consider the following:
The Goodlad Canyon differs significantly in morphology from those in Northern KZN, where coelacanths have been reported and therefore it is unlikely that coelacanths will be found here”.
How can they possibly state this? The first coelacanth was discovered in East London off the Chalumna River. No-one knows where it came from but it certainly did not swim there all the way from Sodwana bay in Northern Zululand. Almost no exploration has taken place in the deep canyons and offshore waters of KZN largely on account of access as there simply are no deep water submersibles available with which to do so, nor is there any funding. The discovery of the coelacanth off northern KZN was purely due to the inshore proximity of the canyon that allowed scuba divers the opportunity of witnessing them. By no stretch of the imagination can it be concluded that they therefore do not occur elsewhere in deep waters off our continental shelf. This statement is therefore entirely false and unprovable and one can only wonder why such bias would present itself in such a report when the coelacanth is considered to be “the most endangered order of animals in the world”1 One shudders to think what the impact on the coelacanth population has been due to the intensive seismic testing that has taken place in these areas during the reconnaissance permit stage!

1 https://en.wikipedia.org/wiki/Coelacanth

Conclusion

The Gulf of Mexico oil spill can be made an example of how offshore oil and gas drilling causes detrimental effects to the ecosystem. Do we not learn anything from history? 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.



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