This week, The Green Connection submitted its comments critiquing several aspects of the Environmental Impact Assessment (EIA) process, particularly the lack of procedural fairness, as well as the conclusions reached – notwithstanding information gaps and scientific uncertainty – that should form part Tosaco Energy’s request to undertake various activities in Block 1, off the West Coast. The environmental justice organisation and local communities on the West Coast in the Northern Cape say they are becoming increasingly frustrated with government and its apparent one-sided support for the oil and gas industry.

The Green Connection’s Strategic Lead Liziwe McDaid says, “Companies like Tosaco, along with governments, seem to downplay the potential damage offshore oil and gas exploration can do to the ocean and environment. This includes downplaying the threat to the livelihoods of small-scale fishers and fishing-dependent communities.”

She says, “A key issue is that government seems willing to break its own rules and regulations to accelerate fossil fuel deals, which really, having regard to the climate change emergency, should be phased out. Since the National Environmental Management Act (NEMA) EIA Regulations make provision for stakeholders to comment on the plan of study in the scoping phase (including what specialist studies are to be undertaken in the subsequent EIA phase), it is worrying that specialist studies were undertaken before the scoping phase.”

“There are several types of impact studies which would help to better understand how the activities from any proposed project might impact small-scale fisher and other communities in the region. However, in this case, even if these communities wanted the EIA to cover more, it was already decided before the EIA commenced that only the marine faunal and the fisheries specialist studies would be done, as well as what each study would entail. Can we then be surprised that both studies predict impacts to range from negligible to low?” she says.

McDaid says The Green Connection, therefore, questions the legality of the decisions taken by Environmental Impact Management Services (EIMS), the consultants working for Tosaco, and the Petroleum Agency of South Africa (PASA) during the pre-application phase. It was at this stage that the two entities colluded in making a decision that two specialist studies would suffice, without affording stakeholders an opportunity to comment on this pre-application decision. She also questions the conclusions reached in the marine faunal specialist desktop study, which was based, in part, on information contained in a generic environmental management programme (EMPR) report commissioned by PASA and co-funded by offshore oil and gas companies.

She says, “How is it legal, or even ethical, that the very entity mandated to promote oil and gas exploration in the country (PASA) is making decisions in the pre-application process, rather than the competent authority (the Department of Mineral Resources and Energy)? The two specialist reports and the draft EIA report clearly reveal several gaps in information and scientific uncertainty – such as the impacts of 3D seismic surveys – relating to marine fauna and ecosystems in Block 1 which include critical biodiversity areas.”

“In addition, no acoustic sound modelling was conducted to assess sound propagation and attenuation in the proposed 3D seismic survey area. We also question the exclusion of an assessment of potential negative impacts of likely future exploration drilling (which was excluded from the scope of this exploration EIA application), such as the risk of catastrophic oil spills resulting from wellhead blowouts, as well as climate change impacts from potential oil and gas drilling, production and end-use should commercially exploitable oil and gas deposits be identified.”

“The Green Connection grows more and more concerned that not enough effort is being made to ensure that all the potential negative impacts of proposed projects are considered, in addition to understanding, quite thoroughly, what implications these could have for small-scale fishers and other communities. We are already witnessing the devastating socioeconomic and environmental impacts of extractive industries, and with the views of stakeholders and potentially-affected communities not being adequately taken into account in decision-making processes, this is a major problem in our country, which must not be ignored,” concludes McDaid.

Andy Pienaar from Kobush Development Association in the Northern Cape says, “We are not satisfied with the handling of the entire process, particularly since many of our people were not represented. Furthermore, while some of the information had been translated we, as the community, did not find the information very accessible. We expect, as is required by the NEMA, that communities who may be affected by the proposed project should be thoroughly involved and understand the information presented. This way we would be in a better position to participate in meaningful ways and ensure that our inputs are also heard and valued. As such, every effort should be made to ensure that those who may be affected are able to attend the discussions.

The presentation itself did not convince us that the prospecting process would not have a negative impact on local fisheries, it did even less to convince us that marine life on our coastline will not be adversely affected. We are worried about the impact exploration and drilling activities will have for the marine protected areas around Block 1, and we are particularly concerned about the economic implications for our people, since there appear to be no alternative opportunities considered for local inhabitants. We therefore reject Tosaco’s application and hope that our government will do the same.”

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