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.
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:
 ‘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. 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. 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.
 Ignoring climate change will yield ‘untold suffering,’ panel of 14,000 scientists warns | Live Science
 Investigating the effects of mobile bottom fishing on benthic biota: a systematic review protocol | Environmental Evidence | Full Text (biomedcentral.com)