TEEPSA 5/6/7 THE WILDLIFE ANIMAL PROTECTION FORUM SOUTH AFRICA MEMBERS SUBMISSION

Monday 4th July 2022

Following the release of the draft scoping report for a 30 day comment period on the 20th May 2022, SLR Consulting received several requests for an extension of the comment period on the Draft Scoping Report. Members of the Wildlife Animal Protection Forum submitted comments today.

TotalEnergies Exploration & Production South Africa (TEEPSA) and its Joint Venture partners invited consultation with interested and affected parties with regard to their proposal to undertake exploratory well drilling in Blocks 5/6/7 a 10 000 square kilometre area between Cape Town and Cape Agulhas.

COPY OF WAPFSA SUBMISSION:

TOTALENERGIES – ESIA FOR PROPOSED EXPLORATION DRILLINGS IN BLOCK 5/6/7

The Wildlife Animal Protection Forum South Africa (WAPFSA) is an alliance of South African based organisations which share certain values, knowledge and objectives and which collectively comprise a body of expertise from scientific, conservation, legal, welfare, rights, social and climate justice, public advocacy sectors.

WAPFSA has registered as an I&AP.

COMMENTS

1. Meaningful Consultation

The undersigning members of WAPFSA believe that the communities living in highly populated areas of the South Western Coast must be meaningfully consulted about the proposed perspective operations which may impact upon their customary rights, which include customary fishing rights and livelihoods. The ocean is also integral to the Khoisan community’s cultural identity and customary system.

These communities should have been engaged with in person (they don`t read national newspapers and cannot be consulted via virtual meetings, nor would they have the opportunity to travel to Cape Town in order to  attend an in-person meeting, such as the meeting which was held in Cape Town on the 9th of June, on a working day at 4h00 pm). 

The TEEPSA project has, in our view, been poorly advertised and the subsequent communication by SLR Consulting has in our experience been inadequate.  

Indigenous communities have strict rules about consultation that emphasise the importance of seeking consensus within the whole community. In the High Court Judgement: Sustaining the Wild Coast NPC vs MRE, Shell Explorations, Case No. 3491/2021 of 28 Dec 2021, it is noted: 

[26]       ‘Meaningful consultation entails providing communities with the necessary information on the proposed activities and affording them an opportunity to make informed representations’. 

WAPFSA members believe that TEEPSA-567 had a duty to meaningfully consult with the communities and individuals who could be impacted by this project.

2. Climate Change

“Ignoring climate change will yield ‘untold suffering,” a panel of 14,000 scientists warned in July 2021, calling for urgent global deal on climate policies[1]. We have reasonable apprehension for irreparable harm on residents and the environment, resulting by both drilling and extracting operations.  

In  May 2022, a Report from the United Nation Office for Disaster Risk Reduction (UNODRR), warned of ‘Total Societal Collapse’ due to breaching of planetary boundaries. The Report is GAR 2022 and was endorsed by UN Secretary-General António Guterres. The report indicated that escalating synergies between disasters, economic vulnerabilities and ecosystem failures are escalating the risk of “global collapse”. For the very first time, the UN has openly flagged that existing global policies are accelerating toward the collapse of human civilisation. 

3. Predicted Impacts, Potential Harm and Risks

We are particularly concerned about all the predicted and unpredicted impacts and risks on people, their businesses and livelihoods and on wildlife and the environment. 

Drilling discharges and normal discharges such as deck drainage, machinery space drainage, sewage and galley wastes from the drilling unit and support vessels will all result in reduction of water quality in the area. Water quality will also be impacted at both local and regional levels due to accidental oil spills during the exploration drilling or in the event of a blow-out. These spills will have adverse effects on marine fauna and will also result in the oiling of coastal habitats and seabirds.

WAPFSA members are concerned about the migration of about 130.000 whales from East Africa trough the prospected areas, towards the Cape where they breed and nurse their young. Concerns also refer to the interference with many delicate species as Turtles, Cape Fur Seals, African Penguins and the Black Oystercatcher. 

These species all stand to be negatively affected by the proposed well drilling, irrespective of whether the project area avoids all MPAs. The fact that the project has even a 5,4% overlap with Critical Biodiversity Areas is a cause for concern as the physiological, mental and emotional effects of the drilling has been seen to cause negative impacts varying in severity, the most severe resulting in death of a variety of marine faunal species. 

In terms of the benthic habitats which might be affected, of the marine species, 98% live on or in the ocean floor[2]. These benthos or bottom dwellers can live buried in the sand, shells or mud or attached to rocks. Sedentary benthic species and other relatively immobile species will experience smothering and biochemical effects, such as direct toxicity and bioaccumulation of the discharge of cuttings, drilling fluid and cement during the well drilling process. The benthic zone maintains a substantial part of the world’s biodiversity. These areas are extensively exploited and destroyed by human activities[3].


[1] Ignoring climate change will yield ‘untold suffering,’ panel of 14,000 scientists warns | Live Science

[2] Thurman, 1991

[3] Investigating the effects of mobile bottom fishing on benthic biota: a systematic review protocol | Environmental Evidence | Full Text (biomedcentral.com)

WAPFSA STATEMENT ON TEEPSA PROPOSED OFFSHORE EXPLORATION IN BLOCK 567 SOUTH WESTERN COAST SOUTH AFRICA

WAPFSA URGES REGISTRATION OF INTERESTED AND AFFECTED PARTIES AND TO COMMENT ON THE “TEEPSA” 567 DRAFT SCOPING REPORT

STATEMENT

Environmental and Social Impact Assessment for the Proposed Offshore Exploration Well Drilling in Block 5/6/7 on the South Western Coast of South Africa.

TotalEnergies Exploration & Production South Africa (TEEPSA) and its Joint Venture partners are inviting consultation with interested and affected parties.

Register Your Concern

TotalEnergies EP South Africa Block 567 (Pty) Ltd (“TEEPSA”) has applied to the Department of Mineral Resources and Energy for Environmental Authorisation to undertake exploration well drilling in Block 567.  

Block 5/6/7 TEEPSA is identified a 10 000 square kilometre area of interest for hydrocarbon exploration approximately 60km from the coast at its closest point and 170km at its furthest. The Area of Interest is located offshore roughly between Cape Town and Cape Agulhas.

Please consider registering as an interested and affected party and comment of the Draft Scoping Report on or before the 4th July 2022.  

Please read the Scoping Report – A Non-Technical Summary: 

https://cdn.slrconsulting.com/uploads/2022-05/TEPSA_567_ESIA_Drill_NTS_220511_Rev6%20ENG.pdf

Registration Documents: 
https://cdn.slrconsulting.com/uploads/2022-05/TEEPSA%20567%20ESIA%20Stakeholder%20DSR%20Letter%20220520_Rev4%20ENG%20GENERAL.pdf

Important Environmental Considerations 

The South-West Coast supports a rich diversity of marine life including sensitive benthic habitats, species, plankton, fish and shark, turtles, seabirds and marine mammals including whales, dolphins and seals. 

There is a marginal overlap with the Vulnerable Cape Canyon habitat ecosystem and there is a 5.4% overlap with Critical Biodiversity Areas. 

There will be up to five wells drilled depending on the success of the first drilling campaign.  Anticipated commencement is between the 4th quarter of 2023 and the 2nd quarter of 2024.  The duration of drilling operation is 3 to 4 months. 

Reason for Concern

Local communities connected to the ocean environment  should be concerned that their way of life might be disrupted. Indigenous communities hold spiritual and cultural connections to the ocean and local small scale fishers may be negatively affected by harm that might be caused to marine life. 

Seabed mining generates constant noise that can be heard over vast areas of ocean.  This noise can cause whales to leave the area, or have impacts likes stress, reduced reproductive success and survivability. 

Deep-sea mining should be halted until the criteria specified by the IUCN are met, including the introduction of assessments, effective regulation and mitigation strategies.  Comprehensive studies are needed to improve our understanding of deep-sea ecosystems and the vital services they provided to people, such as food and carbon sequestration. Species such as whales, tuna and sharks could be affected by noise, vibrations light pollution caused by mining equipment and surface vessels.

Reports suggests that noise pollution produced by deep-sea mining activities could have far-reaching effects on the marine environment, from surface to seafloor.  

Deep-sea mining is a potential risk with environmental consequences due to the continuous low level noise and the sediment that will be stirred up which could impact upon mammals livelihood.  

Scientists and environmentalists urging an international moratorium on deep-sea mining after releasing a report indicating its impact on the Pacific Ocean that would be severe, extensive and last for generations. 

Image Credit: Hermanus Whales

©WAPFSA 2022.  All Rights Reserved.

HOPE, A TAIJI MINKE WHALE

THE KILLING OF THE MINKE WHALE IN TAIJI, JAPAN

AN OPEN LETTER FROM THE WILDLIFE ANIMAL PROTECTION FORUM SOUTH AFRICA

18TH JANUARY 2021

ADDRESSED TO:

Taiji Fisheries Cooperative

Mr. Ryutaro Yatsu
Vice-Minister for Global Environmental Affairs Ministry of Environment

Ms. Kaoru Oka
General Manager Environmental Policy Group

Ms. Kozue Hoshino
Global Environment Division, International Cooperation Bureau Ministry of Foreign Affairs

Mr. Satoru Lino
Deputy Director
Policy Planning Division Environmental Health Department and Department of the Environment

Mr. Teruhiko Shinada
Senior Coordinator
Global Environment Division International Cooperation Bureau Ministry of Foreign Affairs

South African Embassy in Japan

Dear Sirs,

The undersigned members of the Wildlife Animal Protection Forum South Africa (WAPFSA) were informed that the minke whale caught on the 25th December 2020 was mercilessly and brutally killed despite the many international appeals to release it.

WAPFSA consists of an alliance of diverse South African organisations and individuals that share certain values, knowledge and objectives that collectively comprise of a body of expertise from scientific, conservation, legal, animals rights, tourism, social justice and public advocacy sectors.

We, the undersigned, echo the sentiments of Ren Yabuki from the Life Investigation Agency: “Despite Japan being a whaling nation, it’s unjustifiable by anyone’s standards to make an animal suffer in such a cruel manner. The Taiji Fisheries Cooperative’s indifference towards animal’s suffering is shocking.”

BACKGROUND

Taiji is a town located in the Higashimuro District, in Wakayama Prefecture in Japan. Taiji is the only town in Japan where drive hunting still takes place on a large scale. The government allows over 2000 cetaceans to be slaughtered or captured.

The Taiji dolphin hunt is based on driving dolphins and other small cetaceans into a small bay where they can be killed or captured for their meat and for sale to dolphinariums. Taiji also has a long connection to Japanese whaling. The annual dolphin hunt provides income for the local residents.

The Taiji hunt has attraction international criticism for many years, a documentary called The Cove in 2009 drew international attention to the hunt and dedicated environmental and animal rights groups have continued to raise objections. Anti-whaling groups such as Sea Shepherd and Greenpeace continue to insist that whaling is cruel and should be regulated. WAPFSA members are in support of all these organisations, we the undersigned to do not support the whaling industry nor do we support the Taiji hunting methods.

In mitigation to the negative international sentiment, the Japanese government has issued statements to say that whale and dolphin hunting are a traditional form of livelihood in Japan and that like other animals whales and dolphins are killed to supply the demand for meat. They maintain that the methods of killing have become more humane in recent years.

THE MINKE WHALE

On the 25th of December 2020 Ren Yabuki, Campaign Director of Life Investigation Agency, in collaboration with the Dolphin Project, documented a minke whale which had become trapped in Taiji’s fishing nets. The offshore nets owned by the Taiji Fisheries Cooperative are in place year-round just outside the Taiji harbour adjacent to the infamous Cove.

Several different species of fish and shark were caught within the same nets, on the 29th of November 2020 a humpback whale got caught in the nets it was released on the 30th of November.

The minke whale was seen, via drone footage, repeatedly charging the net, with deep diving, likely in attempts to escape. Despite numerous appeals the Taiji Fisheries Cooperative refused to release the whale.

On the 11th of January, the world watched in horror the video of the deliberate killing of the mammal. Eighteen days after the juvenile animal became trapped, fishermen tied a rope around its tail and secured it to their vessel in a way that forcibly kept the the whale’s head underwater. The mammal was seen fighting in panic for at least 20 minutes before drowning. The act was clearly inhumane and cruel and was defined by many as “sadistic”.

WAPFSA STATEMENT

The undersigned members of WAPFSA hereby voice their disappointment that the Taiji Fisheries Cooperative refused to release the minke whale. We hereby collectively add our voices from South Africa to join the many other organisations who have already appealed to the Japanese authorities to change their policies.

If the Japanese government maintains that the methods of killing have become more humane in recent years, why, then, has nothing been done to prevent, nor to respond to such callous incident?

We are deeply saddened and angry that the minke whale was not released and was, instead, forced to suffer and die in this inhumane fashion. We appeal to the Japanese government to urgently review their methods of set net fishing, as well as their bycatch quota and non-target species release policies.

Yours Sincerely,

Megan Carr Founder Rhinos in Africa and Prathna Singh Sea Shepherd South Africa On behalf of WAPFSA

WAPFSA CO-ORDINATOR
Stefania Falcon stefania@emsfoundation.org.za

Supporting Wildlife Animal Protection Forum South Africa Members:

Wynter Worsthorne Founder Animal Talk Africa

Sairusha Govindsamy Founder Africa Climate Alliance

Jenni Trethowan Founder Baboon Matters

Smaragda Louw Director Ban Animal Trading South Africa

Lorraine Holloway Director Baboons of the South

Toni Brockhoven Chairperson Beauty Without Cruelty South Africa

Samantha Dewhirst Director Centre for Animal Rehabilitation and Education

Michele Pickover Director The EMS Foundation

Stephen Fritz Chief South Peninsula Khoi Council

Fiona Miles Director Four Paws South Africa

Stefania Falcon Founder Future 4 Wildlife South Africa

Jabu Myeni Founder Gifted for Good

Linda Tucker CEO Founder Global White Lion Protection Trust

Les Mitchell Director Institute for Critical Animal Studies (Africa)

Steve Smit Co-Founder Monkey Helpline

Kim Da Ribeira Director OSCAP-Outraged SAfrican Citizens Against Poaching

Vivien Law Parliament for the People

Lex Abnett Director Southern African Fight for Rhinos

Dave Du Toit Founder Vervet Monkey Foundation

Sera Farista Youth Climate Group

Guy Jennings Director WildAid Southern Africa

IMAGE CREDIT: Ren Yabuki/Life Investigation Agency

© 2021 WAPFSA. All rights reserved

MARINE OIL POLLUTION Preparedness, Response and Cooperation Draft Bill 2019

WAPFSA has expressed our concern about the seeming lack of infrastructure to prevent and manage emergencies and possible incidents at sea, as well as illegal activities and pollution.

We welcome the Draft Bill as a tool to better protect our biodiversity and environment for the sake of ecosystems and resources for our future generations.

PLEASE READ THE FULL DOCUMENT

OCTOPUS TRAPS IN FALSE BAY MINISTER CREECY’S SECOND RESPONSE TO WAPFSA

“The Department has a mandate to implement the Marine Living Resources Act, which confers the responsibility for ensuring utilisation of marine living resources and protection of the broader ecosystems in which such utilisation may take place, while also achieving social and economic goals, as was re-iterated in the judgement in the West Coast rock lobster case referred to. As a public trustee, I am bound to uphold this legislation and to ensure that the objectives of the Marine Living Resources Act are achieved in a balanced manner”.

Minister Barbara Creecy Department of the Environment, Forestry and Fisheries

OCTOPUS TRAPS IN FALSE BAY THE WILDLIFE ANIMAL PROTECTION FORUM SOUTH AFRICA A SECOND LETTER TO MINISTER CREECY

The undersigned Members of the Wildlife Animal Protection Forum South Africa support the Agenda 2030 Sustainable Development Goals, of which South Africa is a signatory, in particular the ending of poverty with the implicit reduction of inequality and the achievement of social justice.

Our constitution highlights our rights as South Africans to having the environment protected. We support equal access to resources at the same time as we support the need to protect our biodiversity for future generations.

The importance of addressing the climate change crisis is paramount. We believe that, as articulated by UNHRC Chief Michelle Bachelet, climate change is the “greatest ever threat to human rights”

It is vital that South Africa is able to demonstrate our commitment to protecting at 17% of each habitat type. Fulfilling our duty in this regard is essential in order to ensure the sustainability of resources for future generations.

SIGNED BY WAPFSA MEMBERS

OCTOPUS TRAPS IN FALSE BAY A RESPONSE FROM MINISTER CREECY

“The creation of new fisheries in South Africa creates opportunities to achieve economic growth, focusing on small and medium enterprise development thereby creating jobs, developing skilled personnel and enhancing economic transformation in the fishing sector. The Octopus vulgarisms species was identified by the fishing industry as the basis of a possible new commercial venture.”

Minister Barbara Creecy Department Environment, Forestry and Fisheries