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HILL/reut 510482_Pletmos Seismic_Final EIA Report_Executive Summary July 2017 EXECUTIVE SUMMARY: FINAL ENVIRONMENTAL IMPACT ASSESSMENT REPORT – 3D SEISMIC SURVEY IN THE PLETMOS BASIN, SOUTHERN CAPE PASA Reference Number: 12/3/322 SRK Project Number 510482 1 INTRODUCTION Sungu Sungu Oil (Pty) Ltd (Sungu Sungu) intends to conduct a 3D seismic survey in a 2 500 km² target area within the 11 224 km² Pletmos Basin, offshore Southern Cape, South Africa, lasting one to three months (the “project”). Sungu Sungu has submitted an application for an Exploration Right in terms of Section 79 of the Mineral and Petroleum Resources Development Act 28 of 2002 (MPRDA), which was accepted by the Petroleum Agency South Africa (PASA) on 19 September 2016. Sungu Sungu was instructed by PASA to undertake an Environmental Impact Assessment (EIA) process in compliance with the EIA Regulations, 2014, promulgated in terms of the National Environmental Management Act 107 of 1998 (NEMA). Sungu Sungu proposes to acquire, process and interpret 3D seismic data over approximately 700 km² in the Pletmos Basin to explore for possible oil and gas reserves. The Basin is located off the South Coast of South Africa, roughly between Knysna in the west and Jeffrey’s Bay in the east. The target area is located at least 12 km offshore and reaches up to 60 km out to sea (refer to Figure 1). Other activities conducted as part of the three-year exploration programme include interpretation and analysis of seismic data, mapping the sequence and seismic stratigraphy, undertaking detailed well analysis and micro- paleontological studies and volumetric and attribute analysis. SRK Consulting (South Africa) Pty Ltd (SRK) has been appointed by Sungu Sungu to undertake the EIA process required in terms of NEMA. Figure 1: Locality Plan

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HILL/reut 510482_Pletmos Seismic_Final EIA Report_Executive Summary July 2017

EXECUTIVE SUMMARY: FINAL ENVIRONMENTAL IMPACT ASSESSMENT REPORT – 3D SEISMIC SURVEY IN THE PLETMOS BASIN, SOUTHERN CAPE

PASA Reference Number: 12/3/322 SRK Project Number 510482

1 INTRODUCTION

Sungu Sungu Oil (Pty) Ltd (Sungu Sungu) intends to

conduct a 3D seismic survey in a 2 500 km² target area

within the 11 224 km² Pletmos Basin, offshore Southern

Cape, South Africa, lasting one to three months (the

“project”). Sungu Sungu has submitted an application for

an Exploration Right in terms of Section 79 of the Mineral

and Petroleum Resources Development Act 28 of 2002

(MPRDA), which was accepted by the Petroleum Agency

South Africa (PASA) on 19 September 2016. Sungu Sungu

was instructed by PASA to undertake an Environmental

Impact Assessment (EIA) process in compliance with the

EIA Regulations, 2014, promulgated in terms of the

National Environmental Management Act 107 of 1998

(NEMA).

Sungu Sungu proposes to acquire, process and interpret 3D

seismic data over approximately 700 km² in the Pletmos

Basin to explore for possible oil and gas reserves. The Basin

is located off the South Coast of South Africa, roughly

between Knysna in the west and Jeffrey’s Bay in the east.

The target area is located at least 12 km offshore and

reaches up to 60 km out to sea (refer to Figure 1).

Other activities conducted as part of the three-year

exploration programme include interpretation and analysis

of seismic data, mapping the sequence and seismic

stratigraphy, undertaking detailed well analysis and micro-

paleontological studies and volumetric and attribute

analysis.

SRK Consulting (South Africa) Pty Ltd (SRK) has been

appointed by Sungu Sungu to undertake the EIA process

required in terms of NEMA.

Figure 1: Locality Plan

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HILL/reut 510482_Pletmos Seismic_Final EIA Report_Executive Summary July 2017

2 GOVERNANCE FRAMEWORK

Sections 24 and 44 of NEMA make provision for the

promulgation of regulations that identify activities which

may not commence without an Environmental

Authorisation (EA) issued by, in this case, PASA. The

Environmental Impact Assessment (EIA) Regulations, 2014

(Government Notice (GN) R982, which came into effect on

8 December 2014), promulgated in terms of NEMA, govern

the process, methodologies and requirements for the

undertaking of EIAs in support of EA applications. The EIA

Regulations are accompanied by Listing Notices (LN) 1-3

(GN R983, 984 and 985 of 2014) that list activities that

require EA.

The EIA Regulations, 2014 lay out two alternative

authorisation processes. Depending on the type of activity

that is proposed, either a Basic Assessment (BA) process or

a Scoping and Environmental Impact Reporting (S&EIR)

process is required to obtain EA. LN 1 and LN3 list

activities that require a BA process, while LN 2 lists

activities that require S&EIR.

SRK has determined that the proposed project triggers an

activity listed in terms of LN 2 of the EIA Regulations, 2014,

requiring an S&EIR (or “full EIA”). The listed activity in

terms of the EIA Regulations, 2014 is included in Table 1.

Table 1: Listed activities triggered by the project

No Description

LN2 (requiring S&EIR)

18 Any activity including the operation of that activity which requires an exploration right as contemplated in section 79 of the Mineral and Petroleum Resources Development Act, 2002 (Act No. 28 of 2002), including associated infrastructure, structures and earthworks.

Consequently, the proponent is obliged to apply for EA for

the project.

3 ENVIRONMENTAL PROCESS

The EIA Regulations, 2014 define the detailed approach to

the S&EIR process, which consists of two phases: the

Scoping Phase and the Impact Assessment Phase (the

current phase) (see Figure 2).

The Scoping Phase was completed in January 2017 and the

Final Scoping Report was accepted by PASA on 15 February

2017. The Impact Assessment Phase is being undertaken

in accordance with the Plan of Study for EIA, included in

the Scoping Report accepted by PASA.

The key objectives of the EIA are to:

Inform Interested and Affected Parties (IAPs) about

the proposed Project and the EIA process followed;

Obtain comments from IAPs (including the relevant

authorities and the public) and ensure that all issues,

concerns and queries raised are fully documented and

addressed in the EIA Report;

Identify and assess potential significant impacts

associated with the proposed development;

Formulate mitigation measures to avoid and/or

minimise impacts and enhance benefits of the Project;

and

Produce an EIA Report that will provide all necessary

information for PASA to decide whether (and under

what conditions) to authorise the proposed Project.

Figure 2: S&EIR Process

*Note: EMP = Environmental Management Programme

4 DESCRIPTION OF THE SITE AND ENVIRONMENT

The study area is located on the South Coast of South

Africa, which stretches from Cape Agulhas to Cape

Padrone. At its closest point, the proposed survey area lies

approximately 12 km offshore of Oyster Bay near Cape St

Francis in the Eastern Cape Province. This offshore region

is dominated by the Agulhas Bank, a large, shallow area of

the continental shelf where it is at its widest along the

South African coast.

The oceanography of the outer Agulhas Bank is greatly

influenced by the warm, fast-flowing Agulhas Current (see

Figure 3). Westerly winds predominate along the South

Coast in winter, frequently reaching gale force strengths.

During summer, easterly wind directions increase

markedly, resulting in roughly similar strength/frequency

of east and west winds during that season.

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Figure 3: The Agulhas Current off the South Coast of South Africa

The inshore area of the Agulhas Bank, especially between

the cool water ridge and the shore, serves as an important

spawning grounds for numerous fish species and squid

(see Figure 5). There is a high diversity of bony fish and

cartilaginous fish associated with the inshore and shelf

waters of the South Coast, many of which are endemic to

the Southern African coastline and form a significant

component of the demersal trawl and long-line fisheries.

Various important commercial fisheries occur in the

Agulhas region, several of which are active in the vicinity of

the proposed project area, most notably squid jig and

south coast rock lobster. Commercial catch are generally

landed at designated fishing harbours, notably Mossel Bay

and Port Elizabeth.

Three globally threatened turtle species are known to

occur as occasional visitors along the South Coast region of

South Africa, namely the green turtle, the loggerhead

turtle, and the leatherback turtle (see Figure 4). The green

turtle is a non-breeding resident along the east coast,

while the loggerhead turtle and the leatherback turtle nest

on beaches of northern Kwazulu-Natal.

Figure 4: Green, loggerhead and leatherback turtles

Resident cetaceans in the vicinity of the project area

include a variety of toothed whale, dolphin and small

baleen whale species. Migratory species found seasonally

along the South Coast of South Africa largely comprise

several large baleen whale species that migrate through

the region during winter from their Antarctic feeding

grounds to their winter breeding grounds (Blue whale, fin

whale and sei whale).

Figure 5: Pletmos Basin composite sensitivity map

Project Location

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Marine Protected Areas (Goukamma, Robberg, Tsitsikama)

and proposed priority areas for the protection of benthic

and pelagic habitats occur within the region. None of these

fall directly within the proposed target area (see Figure 5).

Several towns and smaller settlements in the Western

Cape and Eastern Cape Provinces are located along the

approximately 225 km long coastal area bordering the

Pletmos Basin, including Knysna, Plettenberg Bay, Nature’s

Valley, Stormsrivier, St Francis Bay and Jeffrey’s Bay.

Particularly St Francis Bay (some 5 000 inhabitants) and

Jeffrey’s Bay (some 27 100 inhabitants) are very popular

with water sport enthusiasts, particularly surfers. Jeffrey’s

Bay is considered one of the world’s best surfing

destinations with a year-round swell. All other settlements

are also popular holiday destinations.

Exploration for oil and gas is currently undertaken in a

number of licence blocks off the western, southern and

eastern coasts of South Africa. Offshore activities off the

South Coast are dominated by oil and gas exploration

activities by PetroSA in Blocks 9 (west of Pletmos) and 11a

(south of Pletmos), Total in Block 11b/12b (south of

Pletmos) and New Age to the east of Pletmos. OK Energy

holds rights to the block located immediately west of the

Pletmos Basin. Oil production / processing also takes place

in Block 9.

5 PROJECT AND PROCESS DESCRIPTION

5.1 Seismic Survey Operation

Seismic surveys are used to obtain information about

underground geology by measuring the differing reflective

properties of sound waves on different rock strata and

underground formations. A pulse of low-frequency

acoustic energy is directed as a wave into the ground

(below the sea floor) and is reflected back to the surface,

where it is received by several cables (streamers) towed

behind the seismic vessel, each containing a string of

sensors (hydrophones) (see Figure 6). The pressure signals

are digitised by the hydrophones and transmitted along

the streamers to recording and processing systems on the

vessel. The data acquired is analysed and used to create a

computer-generated image of the subsurface geology.

Figure 6: Typical offshore seismic survey operation

Two-dimensional (2D) and three-dimensional (3D) data can

be obtained in this way. During 2D seismic surveys, the

seismic vessel tows the sound wave source (airguns) and

hydrophone streamers in a single, predetermined line.

During 3D seismic surveys, the vessel covers a larger area

in a racetrack pattern, which basically consists of closely-

spaced 2D lines and generates much more data than a

single 2D line. Sungu Sungu proposed to conduct a one to

three-month 3D seismic survey.

5.2 Seismic Survey Equipment

Offshore seismic surveys are undertaken with purpose-

built or converted vessels. The seismic vessel tows the

energy (sound) sources, which are typically pneumatic

devices (airguns) that can release high-pressure air into the

surrounding water and the seabed, as well as the

streamers that contain the hydrophones.

Figure 7: Solid hydrophone streamers

Survey vessels are typically equipped with airguns of

various sizes. The survey vessel that will conduct the

survey in the Pletmos Basin is expected to be equipped

with a 3 624 in³ tune bolt airgun array with three strings of

airguns, the size and configuration of which will be

confirmed once a contractor has been appointed.

Eight to twelve hydrophone steerable solid streamers,

each 8-12 km long, will be used during the survey.

Streamers will be pulled at a distance of 100 m from each

other, resulting in a total streamer spread of 800 to

1 200 m. A number of floats and diverters will be

employed to maintain the spread and streamer depth

below the sea surface (see Figure 8).

A tail buoy is connected to the end of each streamer to

alert other vessels to the submerged streamer (especially

at night) and is equipped with a Global Positioning System

(GPS) for navigation.

Figure 8: Typical seismic survey towed configuration

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A ‘chase boat’ is used to patrol the survey area and warn

any other vessels about the operation, the presence of the

seismic streamers and the limited manoeuvrability of the

seismic vessel. It is expected that at least one support

vessel and chase boat will be employed during the seismic

survey in the Pletmos Basin.

The survey vessel cannot stop and must continue moving

at an average speed of 5 knots. Due to the vessel’s limited

manoeuvrability, a ‘safety zone’ is in place around the

vessel and towing configuration. The dimensions of this

safety zone are at least 5 km ahead of the vessel, 10 km

behind the vessel and 2 km to either side.

5.3 Operational Emissions and Discharges

Several types of wastes, emissions and discharges will be

generated during the seismic survey. These include:

Noise emissions from the airguns, which typically

produce sound levels at approximately 250 dB re 1 mPa

@ 1m with low frequencies (<300 Hz), as well as from

the vessels’ engines and helicopter;

Air emissions from the seismic vessel’s engines and

generators as well as the supply boat, chase boats and

helicopters. A typical seismic survey vessel will

consume between 20 000 and 30 000 litres of fuel per

day, which translates roughly to the emission of

between 56 and 93 tonnes of greenhouse gases;

Drainage and ballast water may contain potential

contaminants from spills or leaks or contain foreign

organisms. All effluent must comply with international

(MARPOL) standards and will then be discharged into

the sea while the vessel is offshore;

Domestic wastewater will include grey water from

washbasins and showers, as well as sewage. Sewage

will be treated in an onboard processing plant. All

effluent must comply with international (MARPOL)

standards and will then be discharged into the sea

while the vessel is offshore; and

General and hazardous waste will generally be

collected in designated waste skips, transported to land

and disposed of through existing waste disposal

facilities and/or contractors.

6 ALTERNATIVES

Appendix 3 Section 3 (h)(i) of the EIA Regulations, 2014,

requires that all S&EIR processes must identify and

describe feasible and reasonable alternatives. Not all

categories of alternatives are applicable to this project:

Location alternatives: Application for an exploration or

production right has to be specific to a block and is

informed by the perceived likelihood of identifying

feasible reserves in the area. Sungu Sungu has lodged

an Exploration Right application for the Pletmos Basin;

therefore no location alternatives will be assessed;

Activity alternatives: In response to stakeholder

comments, 2D and 3D survey methods were

considered. These are used for different purposes, and

are thus not alternatives per se. Only the 3D survey

method is deemed feasible by Sungu Sungu to achieve

the aims of the survey;

Technology alternatives: Seismic surveys require highly

specialised technology and skills, and technology

alternatives are constrained by the best available

proven technology for conducting seismic surveys.

While alternative technologies are being investigated,

these are not yet fully developed and commercially

available; and

The No-Go alternative: The No Go alternative is

considered in the EIA in accordance with the

requirements of the EIA Regulations, 2014. The No-Go

alternative entails no change to the status quo, in other

words, the proposed 3D seismic survey will not be

conducted in the Pletmos Basin.

7 STAKEHOLDER ENGAGEMENT

Stakeholder engagement is a key component of the S&EIR

process and is being undertaken in accordance with

Chapter 6 of the EIA Regulations, 2014. The key

stakeholder engagement activities during the EIA process

are summarised in Table 2 below.

Table 2: Stakeholder Engagement during Impact Assessment Phase

Activity Date

Scoping Phase

Advertise EIA process and release Scoping Report for comment

17 / 18 Nov 2016

Comment period 21 Nov 2016 – 12 Jan 2017

Impact Assessment Phase

Release EIA Report for comment 11 Apr 2017

Comment period 12 Apr 2017 - 15 Jun 20171

Public Open Day 1 3 May (Plettenberg Bay)

Public Open Day 2 4 May (St Francis Bay)

The Public Open Days were attended by ~94 stakeholders,

predominantly in Plettenberg Bay. Some 400 stakeholder

comments and a petition signed by 1 186 people were

received following the release of the EIA Report for public

comment. A detailed list of all stakeholders who submitted

comments is provided in the Issues and Responses

Summary in Appendix G of the Final EIA Report.

1 Based on a stakeholder request, the comment period on the EIA Report was extended by one month to 15 June 2017.

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The main issues raised by stakeholders on the contents of

the EIA Report are:

The seismic survey may have significant ecological

impacts, specifically on marine fauna, due to the

generation of underwater noise and the proximity of

areas of environmental importance, as evidenced by the

designation of national and international important /

protected areas in the vicinity;

The seismic survey may impact on marine fauna

through entanglement in survey equipment or offshore

water pollution;

The project may have significant economic impacts if it

affects fishing stocks (particularly squid) and / or

tourism;

The seismic survey is not compatible with the pristine

and natural sense of place of the Garden Route;

Possible subsequent exploitation of oil and gas is not

desirable, as it might have significant effects on marine

fauna and associated economic activities;

Alternative sources of energy should be explored;

More primary research should be conducted in the

project area to inform the impact assessment;

If approved, the survey should be conducted from July

to September, rather than February to May as

recommended in the EIA Report; and

More information is required about Sungu Sungu and

their ability to conduct the survey and remedy any

impacts that may arise.

8 ASSESSMENT OF POTENTIAL IMPACTS

The following specialist studies were undertaken to

investigate key potential direct, indirect and cumulative

impacts:

Marine Ecology Impact Assessment; and

Fisheries Impact Assessment.

The following potential impacts of seismic survey activities

were identified as being of minor significance:

Reduction in local air quality;

Noise from vessel movement and helicopter flights

affecting marine and coastal fauna;

Small spills of hydrocarbons affecting marine

organisms;

Introduction of exotic marine species into local waters

displacing local species;

Disturbance of and damage to the benthic

environment;

Increase in marine traffic and vessel collision risk;

Vessel lighting disturbing marine fauna and birds;

Discharge of wastewater affecting water quality and

marine organisms;

Employment creation; and

Contribution to the national economy.

For all potentially significant impacts, the significance of

the anticipated impact was rated without and with

recommended mitigation measures. These impacts are

presented in Table 4.

The significance of potential impacts of the proposed

project was determined to assist decision-makers.

Relevant observations with regard to the overall impact

ratings, assuming mitigation measures are effectively

implemented, are:

The predicted marine ecology impacts, mainly

associated with possible injury to or altered behaviour

of marine fauna, are rated as low, very low or

insignificant. Cetaceans are of greatest concern,

particularly during migration periods, as are possible

injuries to seabirds and turtles. Whale migration

periods should be avoided in terms of international

best practice. Periods during which no seismic survey

should be conducted are also suggested for penguins,

fish and squid;

The predicted fishery impacts are rated as very low,

provided that certain periods are avoided to avoid

impacts on the hake, south coast rock lobster and squid

jig industries. The squid jig industry is considered most

sensitive in this regard; and

The predicted socio-economic impact on coastal

(tourism) activities, notably recreational scuba diving, is

rated as very low, as no diving activities should take

place within several kilometres of the survey vessel.

Cumulative impacts in the region may derive from existing

and future oil and gas exploration and exploitation

activities, fishing and vessel traffic. The incidence and

frequency of exploration and exploitation activity along

the South African coast are still relatively low, and

significant cumulative impacts are only expected if

simultaneous seismic surveys take place in relatively close

proximity to each other and/or shortly after each other,

which is deemed unlikely at present.

Table 3 below summarises:

The impacts assessed in the EIA;

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Their significance before and following the

implementation of essential mitigation measures, on

which the significance rating is based; and

The key (non-standard essential) mitigation measures.

The project does not have distinct construction or

operational phases. As such, the impacts discussed below

relate to the impacts of the seismic survey.

Impact significance ratings legend:

Rating +ve -ve

Insignificant I I

Very Low VL VL

Low L L

Medium M M

High H H

Very High VH VH

Table 3: Summary of impacts

Impact

Significance rating Key selected non-standard mitigation/optimisation measures

(repeated items are only included the first time) Without Mitig.

With

Mitig.

POTENTIAL MARINE ECOLOGY IMPACTS

Injury or behavioural changes in plankton

I I None

Injury or behavioural changes in inverte-brates (excl. squid)

I I None

Injury or behavioural changes in squid

VL I Implement airgun “soft-starts” of at least 20 minutes duration.

Avoid surveying during the peak squid spawning periods between early September and late December, if possible.

Injury or behavioural changes in fish

L I Do not undertake seismic survey activities within Marine Protected Areas.

Undertake the survey from February to late May to avoid the key fish spawning period in spring and early summer, if possible.

Injury or behavioural changes in seabirds

M I

Wait until all diving seabirds have cleared an area of 500 m radius of the centre of the airgun arrays before commencing airgun firing.

Employ onboard Independent Observer(s) / MMO(s).

Record seabird incidences and behaviour.

Suspend operations in the event of any obvious mortality or injuries to seabirds as a direct result of the survey.

Avoid surveying during the pre-moult and post-moult period for African Penguins from October to March, if possible.

Injury or behavioural changes in turtles

M VL

Wait until all turtles have cleared an area of 500 m radius of the centre of the airgun arrays before commencing airgun firing.

Record turtle incidences and behaviour and their responses to seismic shooting.

Suspend seismic shooting when obvious mortality or injuries to turtles as a direct result of the survey are observed.

Suspend operations if any obvious negative changes to turtle behaviour are observed from the survey vessel, or animals are observed within the immediate vicinity (within 500 m) of operating airguns and appear to be approaching firing airgun.

Use ‘turtle-friendly’ tail buoys or fit existing tail buoys with either exclusion or deflector 'turtle guards'.

Injury or behavioural changes in seals

VL I

Wait for at least 30 min until all seals have cleared an area of 500 m radius of the centre of the airgun arrays before commencing airgun firing. If, after a period of 30 minutes, seals are still within 500 m of the airguns, the normal “soft start” procedure should be allowed to commence for at least a 20-minutes duration.

Employ onboard Independent Observer(s) / MMO(s) with experience in seabird, turtle and marine mammal identification and observation techniques to carry out daylight observations of the survey region.

Suspend seismic shooting when obvious negative changes to seal behaviour is observed from the survey vessel.

Record obvious mortality or injuries to seals as a direct result of the survey.

Injury or behavioural changes in whales and dolphins

M L

Ensure that the survey vessel is fitted with Passive Acoustic Monitoring (PAM) technology with two hydrophones to allow directional detection of cetaceans. Ideally tow the PAM hydrophone streamer behind the air-gun array to minimise the interference of vessel noise.

Ensure that the survey vessel is fitted with thermal imaging cameras if (a portion of) the survey is conducted between June and December.

Use PAM technology in combination with thermal imaging cameras 24-hours to monitor

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Impact

Significance rating Key selected non-standard mitigation/optimisation measures

(repeated items are only included the first time) Without Mitig.

With

Mitig.

for the presence of cetaceans near the survey operations as follows:

June to December: Day time: Visual observation and PAM technology and Night time and periods of poor daytime visibility: PAM technology and infra-red technology;

January to May: Day time: Visual observation and Night time and periods of poor daytime visibility: PAM technology;

Record marine mammal incidences and responses to seismic shooting, inlcuding data on position, distance from the vessel, swimming speed and direction and obvious changes in behaviour (e.g. startle responses or changes in surfacing/diving frequencies, breathing patterns) along with seismic noise levels.

Wait until cetaceans have cleared an area of 500 m radius of the centre of the airgun arrays for at least 30 min before commencing airgun firing.

Suspend seismic shooting when obvious changes to cetacean behaviour are observed from the survey vessel, or animals are observed within the immediate vicinity (within 500 m) of operating air-guns and appear to be approaching firing air-gun.

Avoid surveying during cetacean migration from June to December, in line with the JNCC best practice guidelines for minimising the risk of injury and disturbance to marine mammals from seismic surveys (JNCC 2010).

Avoid surveying during the following periods, as far as possible:

o September to December (peak squid spawning);

o June to January (fish spawning);

o October to March (pre-moult and post-moult period for African Penguins).

POTENTIAL SOCIO-ECONOMIC IMPACTS

Reduced catch by demersal trawl sector

VL VL

Notify the operators of offshore and inshore trawl vessels of the survey timing, area and safety clearance requirements prior to the commencement of the survey through the South African Deepsea Trawling Industry Association (SADSTIA) and the South East Coast Inshore Fishing Association (SECIFA).

Ensure that Daily Coastal Navigational Warnings are issued via the South African Navy Hydrographic Office (SANHO).

Maintain adequate safety clearance between fishing vessels and survey operation through at-sea communications with vessels in the vicinity of the survey area.

Reduced catch by mid-water trawl sector

VL VL Notify the operators of mid-water trawl vessels of the survey timing, area and safety

clearance requirements prior to the commencement of the survey through the South African Midwater Trawling Association and Oceana Group Ltd.

Reduced catch by demersal long-line (hake) sector

VL VL

Notify the operators of demersal long-line vessels of the survey timing, area and safety clearance requirements prior to the commencement of the survey through the South Africa Hake Longline Association (SAHALLA).

Undertake the survey from January to March (inclusive), when fishing effort is lower.

Reduced catch by demersal long-line (shark) sector

VL VL Notify the operators of demersal long-line vessels of the survey timing, area and safety

clearance requirements prior to the commencement of the survey through the Shark Longline Association.

Reduced catch by large pelagic long-line sector

I I Notify the operators of pelagic long-line vessels of the survey timing, area and safety

clearance requirements prior to the commencement of the survey through the South Africa Tuna Longline Association (SATLA).

Reduced catch by traditional line-fish sector

VL VL Notify the linefish vessel operators of the survey timing, area and safety clearance

requirements prior to the commencement of the survey through the South African Marine Linefish Management Association (SAMLMA).

Reduced catch by small pelagic purse-seine sector

VL VL Notify the operators of purse-seine vessels of the survey timing, area and safety

clearance requirements prior to the commencement of the survey through the South African Pelagic Fishing Industry Association (SAPFIA).

Reduced catch by south coast rock lobster sector

L VL

Notify the operators of rock lobster vessels of the survey timing, area and safety clearance requirements prior to the commencement of the survey through the South Coast Rock Lobster Association.

Undertake the survey from June to September, when south coast rock lobster fishing effort is lower.

Reduced catch by squid jig sector

M VL

Notify fishermen of the survey timing, area and safety clearance requirements prior to the commencement of the survey through the South African Squid Management Industrial Association (SASMIA).

Undertake the survey from February to September when squid fishing effort is lower.

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Impact

Significance rating Key selected non-standard mitigation/optimisation measures

(repeated items are only included the first time) Without Mitig.

With

Mitig.

Reduced opportunity for DAFF research survey

L I

Notify DAFF of the survey timing, area and safety clearance requirements prior to the commencement of the survey.

Ensure that Daily Coastal Navigational Warnings are issued via the South African Navy Hydrographic Office (SANHO).

Maintain adequate safety clearance between the research vessel and survey operation through on-going at-sea communications as necessary.

Implement air gun “soft starts” of at least 20 minutes.

Disruption of coastal (tourism) activities

VL VL

Notify coastal water users, notably dive operators, of the location and schedule of the seismic survey.

If diving operations are scheduled within 15 km of the survey area, establish a communication protocol with diving operators to ensure the survey vessel does not enter within 15 km of divers in the water.

9 CONCLUSIONS AND RECOMMENDATIONS

9.1 Principal Findings

The potentially significant environmental impacts associated

with the proposed seismic survey considered in the S&EIR

process include marine ecology and socio-economic

(including fisheries and coastal tourism activities).

Key mitigation relates to the detection, observation and

avoidance of marine fauna in the vicinity of the survey

vessel, notification of fishing sectors of the exclusion zones

associated with the survey vessel and avoidance of certain

periods that are of particular importance to certain marine

fauna and/or fishing sectors.

The EIA has identified periods of particular importance to

certain marine fauna and/or fishing sectors, during which

seismic surveys should ideally be avoided to reduce adverse

impacts. In combination, sensitive periods occur throughout

the year: consequently there is no single, ideal

window/period to conduct the seismic survey so as to

further reduce all impacts.

Noting the particular importance and sensitivity of longer-

lived and endangered mammals, notably cetaceans, it is

recommended that the survey takes place outside of the

cetacean migration period. Also considering the importance

of January for fish and squid spawning and squid fishing

sector, it is recommended that the survey is conducted in

the period from February to May, when impacts are largely

minimised.

The impacts associated with the seismic survey, particularly

if undertaken in the clearly preferable period from February

to May, are considered to be acceptable. If the survey is

undertaken outside of this period, pre-mitigation impacts

are rated to be of medium to low significance. Additional

delays to the survey are likely, owing to the increased

presence of cetaceans in the area, and significant

stakeholder concern is anticipated.

The seismic survey does not involve the placement of any

physical infrastructure. As such, there is no need for

decommissioning or rehabilitation at the end of the seismic

survey, or financial provisions in this respect.

The No-Go alternative implies no change to the status quo

and thus no additional impacts on marine ecology or

fisheries relative to the current situation. As such, the No-Go

alternative is preferable from an environmental and socio-

economic perspective at present; however, it precludes the

possible discovery and future exploitation of oil and gas

resources in the Pletmos Basin, which are desired in terms

of national policy.

A number of mitigation and monitoring measures have been

identified to avoid, minimise and manage potential

environmental impacts associated with the proposed

development. These are further laid out in the EMPr.

The stakeholder engagement process has identified

considerable stakeholder opposition to the project,

expressed in some 400 written submissions and an online

petition signed by 1 186 people. Opposition is based mainly

on the perceived significance of impacts on marine fauna

(due to underwater noise), associated impacts on the fishing

and tourism industries and the proximity of areas of

environmental importance.

9.2 Need and Desirability

The analysis of need and desirability of the project indicates

that the survey complies with and responds directly to a

number of national policies by facilitating exploration of

South African oil and gas resources. It does not fully comply

with certain social, economic and ecological planning

objectives, as the seismic survey may affect fisheries and

can cause behavioural changes and disturbance of sensitive

and internationally protected marine fauna, although

injuries and death are less likely if standard mitigation

measures are applied. Impacts can be minimised by

scheduling the survey in the period from February to May.

SRK Consulting: Sungu Sungu Pletmos Basin Seismic Survey – Final EIA Report Executive Summary Page - 10 -

HILL/REUT 510482_Pletmos Seismic_Final EIA Report_Executive Summary July 2017

9.3 Authorisation Opinion

This EIA Report has identified and assessed the potential

biophysical and socio-economic impacts associated with the

proposed 3D seismic survey in the Southern Cape.

SRK believes that sufficient information is available for PASA

to take a decision regarding authorisation of the

development.

The seismic survey will result in unavoidable adverse

environmental impacts, although these are of relatively

limited extent, given the limited footprint of the target area

(relative to the Pletmos Basin), relatively short duration of

the survey and transient nature of the seismic survey (no

physical infrastructure will be installed). Consequently, none

of these adverse impacts are considered unacceptably

significant and all can be managed to tolerable levels

through the effective implementation of the recommended

mitigation measures.

Working on the assumption that Sungu Sungu is committed

to ensuring that the seismic survey is done to high

environmental standards, achieved through implementation

of the recommended mitigation measures and ongoing

monitoring of performance, SRK believes and the EIA Report

demonstrates that through effective implementation of the

stipulated mitigation measures, the adverse impacts can be

reduced to levels compliant with national (and

international) standards or guidelines.

SRK believes that the specialist studies have shown that the

seismic survey is generally acceptable. The EIA has also

assisted in the identification of essential mitigation

measures that will mitigate the impacts associated with

these components to within tolerable limits.

The fundamental decision is whether to allow the survey,

which does not provide tangible economic or social benefits

at the present, pending the identification of viable resources

and feasibility of exploitation at a later stage, and has met

with considerable stakeholder opposition, but which is

deemed to have limited biophysical and social impacts.

In conclusion SRK is of the opinion that on purely

‘environmental’ grounds (i.e. the project’s potential socio-

economic and biophysical implications) the application as it

is currently articulated can be approved. February to May

are the most suitable months for the seismic survey, when

impacts are largely minimised and would demonstrate

compliance with best practice.

9.4 Way Forward

The public participation process conducted to date has given

stakeholders the opportunity to assist with the identification

of issues and potential impacts, and to submit their

comments. Comments have been incorporated into the Final

EIA Report, which is now being submitted to PASA.