EXECUTIVE SUMMARY: 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 is located off the South Coast of , roughly between Knysna in the west and Jeffrey’s Bay in the east. Sungu Sungu Oil (Pty) Ltd (Sungu Sungu) intends to The target area is located at least 12 km offshore and conduct a 3D seismic survey in a 2 500 km² target area reaches up to 60 km out to sea (refer to Figure 1). within the 11 224 km² Pletmos Basin, offshore Southern Other activities conducted as part of the three-year Cape, South Africa, lasting one to three months (the exploration programme include interpretation and analysis “project”). Sungu Sungu has submitted an application for of seismic data, mapping the sequence and seismic an Exploration Right in terms of Section 79 of the Mineral stratigraphy, undertaking detailed well analysis and micro- and Petroleum Resources Development Act 28 of 2002 paleontological studies and volumetric and attribute (MPRDA), which was accepted by the Petroleum Agency analysis. South Africa (PASA) on 19 September 2016. Sungu Sungu was instructed by PASA to undertake an Environmental SRK Consulting (South Africa) Pty Ltd (SRK) has been Impact Assessment (EIA) process in compliance with the appointed by Sungu Sungu to undertake the EIA process EIA Regulations, 2014, promulgated in terms of the required in terms of NEMA. National Environmental Management Act 107 of 1998

(NEMA). See page - 10 - for details on how you

Sungu Sungu proposes to acquire, process and interpret 3D can participate in the process. seismic data over approximately 700 km² in the Pletmos Basin to explore for possible oil and gas reserves. The Basin

Figure 1: Locality Plan

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 Identify and assess potential significant impacts 2 GOVERNANCE FRAMEWORK associated with the proposed development; Sections 24 and 44 of NEMA make provision for the  Formulate mitigation measures to avoid and/or promulgation of regulations that identify activities which minimise impacts and enhance benefits of the Project; may not commence without an Environmental and Authorisation (EA) issued by, in this case, PASA. The  Produce an EIA Report that will provide all necessary Environmental Impact Assessment (EIA) Regulations, 2014 information for PASA to decide whether (and under (Government Notice (GN) R982, which came into effect on what conditions) to authorise the proposed Project. 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 Figure 2: S&EIR Process the project. *Note: EMP = Environmental Management Programme

3 ENVIRONMENTAL PROCESS 4 DESCRIPTION OF THE SITE AND ENVIRONMENT

The EIA Regulations, 2014 define the detailed approach to The study area is located on the South Coast of South the S&EIR process, which consists of two phases: the Africa, which stretches from Cape Agulhas to Cape Scoping Phase and the Impact Assessment Phase (the Padrone. At its closest point, the proposed survey area lies current phase) (see Figure 2). approximately 12 km offshore of Oyster Bay near Cape St The Scoping Phase was completed in January 2017 and the Francis in the Province. This offshore region Final Scoping Report was accepted by PASA on 15 February is dominated by the Agulhas Bank, a large, shallow area of 2017. The Impact Assessment Phase is being undertaken the continental shelf where it is at its widest along the in accordance with the Plan of Study for EIA, included in South African coast. the Scoping Report accepted by PASA. The oceanography of the outer Agulhas Bank is greatly The key objectives of the EIA are to: influenced by the warm, fast-flowing Agulhas Current (see  Inform Interested and Affected Parties (IAPs) about Figure 3). Westerly winds predominate along the South the proposed Project and the EIA process followed; Coast in winter, frequently reaching gale force strengths.  Obtain comments from IAPs (including the relevant During summer, easterly wind directions increase authorities and the public) and ensure that all issues, markedly, resulting in roughly similar strength/frequency concerns and queries raised are fully documented and of east and west winds during that season. addressed in the EIA Report;

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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 . 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 Project Location 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 3: The Agulhas Current off the South Coast of South Africa The inshore area of the Agulhas Bank, especially between Figure 4: Green, loggerhead and leatherback turtles the cool water ridge and the shore, serves as an important Resident cetaceans in the vicinity of the project area spawning grounds for numerous fish species and squid include a variety of toothed whale, dolphin and small (see Figure 5). There is a high diversity of bony fish and baleen whale species. Migratory species found seasonally cartilaginous fish associated with the inshore and shelf along the South Coast of South Africa largely comprise waters of the South Coast, many of which are endemic to several large baleen whale species that migrate through the Southern African coastline and form a significant the region during winter from their Antarctic feeding component of the demersal trawl and long-line fisheries. grounds to their winter breeding grounds (Blue whale, fin whale and sei whale).

Figure 5: Pletmos Basin composite sensitivity map

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Marine Protected Areas (Goukamma, Robberg, Tsitsikama) Two-dimensional (2D) and three-dimensional (3D) data can and proposed priority areas for the protection of benthic be obtained in this way. During 2D seismic surveys, the and pelagic habitats occur within the region. None of these seismic vessel tows the sound wave source (airguns) and fall directly within the proposed target area (see Figure 5). hydrophone streamers in a single, predetermined line. During 3D seismic surveys, the vessel covers a larger area Several towns and smaller settlements in the Western in a racetrack pattern, which basically consists of closely- Cape and Eastern Cape Provinces are located along the spaced 2D lines and generates much more data than a approximately 225 km long coastal area bordering the single 2D line. Sungu Sungu proposed to conduct a one to Pletmos Basin, including Knysna, Plettenberg Bay, Nature’s three-month 3D seismic survey. Valley, Stormsrivier, and Jeffrey’s Bay. Particularly St Francis Bay (some 5 000 inhabitants) and 5.2 Seismic Survey Equipment Jeffrey’s Bay (some 27 100 inhabitants) are very popular Offshore seismic surveys are undertaken with purpose- with water sport enthusiasts, particularly surfers. Jeffrey’s built or converted vessels. The seismic vessel tows the Bay is considered one of the world’s best surfing energy (sound) sources, which are typically pneumatic destinations with a year-round swell. All other settlements devices (airguns) that can release high-pressure air into the are also popular holiday destinations. surrounding water and the seabed, as well as the Exploration for oil and gas is currently undertaken in a streamers that contain the hydrophones. 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 Figure 7: Solid hydrophone streamers Pletmos Basin. Oil production / processing also takes place in Block 9. 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 5 PROJECT AND PROCESS DESCRIPTION with a 3 624 in³ tune bolt airgun array with three strings of airguns, the size and configuration of which will be 5.1 Seismic Survey Operation confirmed once a contractor has been appointed. Seismic surveys are used to obtain information about Eight to twelve hydrophone steerable solid streamers, underground geology by measuring the differing reflective each 8-12 km long, will be used during the survey. properties of sound waves on different rock strata and Streamers will be pulled at a distance of 100 m from each underground formations. A pulse of low-frequency other, resulting in a total streamer spread of 800 to acoustic energy is directed as a wave into the ground 1 200 m. A number of floats and diverters will be (below the sea floor) and is reflected back to the surface, employed to maintain the spread and streamer depth where it is received by several cables (streamers) towed below the sea surface (see Figure 8). behind the seismic vessel, each containing a string of sensors (hydrophones) (see Figure 6). The pressure signals A tail buoy is connected to the end of each streamer to are digitised by the hydrophones and transmitted along alert other vessels to the submerged streamer (especially the streamers to recording and processing systems on the at night) and is equipped with a Global Positioning System vessel. The data acquired is analysed and used to create a (GPS) for navigation. computer-generated image of the subsurface geology.

Figure 8: Typical seismic survey towed configuration Figure 6: Typical offshore seismic survey operation

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A ‘chase boat’ is used to patrol the survey area and warn an Exploration Right application for the Pletmos Basin; any other vessels about the operation, the presence of the therefore no location alternatives will be assessed; seismic streamers and the limited manoeuvrability of the  Activity alternatives: In response to stakeholder seismic vessel. It is expected that at least one support comments, 2D and 3D survey methods were vessel and chase boat will be employed during the seismic considered. These are used for different purposes, and survey in the Pletmos Basin. are thus not alternatives per se. Only the 3D survey The survey vessel cannot stop and must continue moving method is deemed feasible by Sungu Sungu to achieve at an average speed of 5 knots. Due to the vessel’s limited the aims of the survey; manoeuvrability, a ‘safety zone’ is in place around the  Technology alternatives: Seismic surveys require highly vessel and towing configuration. The dimensions of this specialised technology and skills, and technology safety zone are at least 5 km ahead of the vessel, 10 km alternatives are constrained by the best available behind the vessel and 2 km to either side. proven technology for conducting seismic surveys. 5.3 Operational Emissions and Discharges While alternative technologies are being investigated, these are not yet fully developed and commercially Several types of wastes, emissions and discharges will be available; and generated during the seismic survey. These include:  The No-Go alternative: The No Go alternative is  Noise emissions from the airguns, which typically considered in the EIA in accordance with the produce sound levels at approximately 250 dB re 1 mPa requirements of the EIA Regulations, 2014. The No-Go @ 1m with low frequencies (<300 Hz), as well as from alternative entails no change to the status quo, in other the vessels’ engines and helicopter; words, the proposed 3D seismic survey will not be  Air emissions from the seismic vessel’s engines and conducted in the Pletmos Basin. generators as well as the supply boat, chase boats and helicopters. A typical seismic survey vessel will 7 STAKEHOLDER ENGAGEMENT consume between 20 000 and 30 000 litres of fuel per day, which translates roughly to the emission of Stakeholder engagement is a key component of the S&EIR between 56 and 93 tonnes of greenhouse gases; process and is being undertaken in accordance with  Drainage and ballast water may contain potential Chapter 6 of the EIA Regulations, 2014. The key contaminants from spills or leaks or contain foreign stakeholder engagement activities during the EIA process organisms. All effluent must comply with international are summarised in Table 2 below. (MARPOL) standards and will then be discharged into Relevant local, provincial and national authorities, the sea while the vessel is offshore; conservation bodies, local forums and surrounding  Domestic wastewater will include grey water from landowners and occupants have been directly notified of washbasins and showers, as well as sewage. Sewage the S&EIR process and the release of the EIA Report for will be treated in an onboard processing plant. All comment. effluent must comply with international (MARPOL) Table 2: Stakeholder Engagement during Impact standards and will then be discharged into the sea Assessment Phase while the vessel is offshore; and Activity Date  General and hazardous waste will generally be Scoping Phase collected in designated waste skips, transported to land Advertise EIA process and release 17 / 18 Nov 2016 and disposed of through existing waste disposal Scoping Report for comment facilities and/or contractors. Comment period 21 Nov 2016 – 12 Jan 2017 Impact Assessment Phase 6 ALTERNATIVES Release EIA Report for comment 11 Apr 2017 Comment period 12 Apr 2017 – Appendix 3 Section 3 (h)(i) of the EIA Regulations, 2014, 16 May 2017 requires that all S&EIR processes must identify and Public Open Day 1 3 May (Plettenberg Bay) describe feasible and reasonable alternatives. Not all Public Open Day 2 4 May (St Francis Bay) categories of alternatives are applicable to this project: Key comments and concerns raised by stakeholders  Location alternatives: Application for an exploration or predominantly relate to: production right has to be specific to a block and is informed by the perceived likelihood of identifying  Potential ecological impacts, specifically on marine feasible reserves in the area. Sungu Sungu has lodged fauna, due to the generation of underwater noise and the proximity to areas of environmental importance;

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 Potential economic impacts if fishing stocks and / or of marine fauna, are rated as low, very low or tourism is affected; and insignificant. Cetaceans are of greatest concern,  The undesirability of the seismic survey and possible particularly during migration periods, as are possible subsequent exploitation of mineral resources due to injuries to seabirds and turtles. Whale migration the above potential impacts. periods should be avoided in terms of international best practice. Periods during which no seismic survey should be conducted are also suggested for penguins, 8 ASSESSMENT OF POTENTIAL IMPACTS fish and squid; The following specialist studies were undertaken to  The predicted fishery impacts are rated as very low, investigate key potential direct, indirect and cumulative provided that certain periods are avoided to avoid impacts: impacts on the hake, south coast rock lobster and squid jig industries. The squid jig industry is considered most  Marine Ecology Impact Assessment; and sensitive in this regard; and  Fisheries Impact Assessment.  The predicted socio-economic impact on coastal The following potential impacts of seismic survey activities (tourism) activities, notably recreational scuba diving, is were identified as being of minor significance: rated as very low, as no diving activities should take  Reduction in local air quality; place within several kilometres of the survey vessel.  Noise from vessel movement and helicopter flights Cumulative impacts in the region may derive from existing affecting marine and coastal fauna; and future oil and gas exploration and exploitation  Small spills of hydrocarbons affecting marine activities, fishing and vessel traffic. The incidence and organisms; frequency of exploration and exploitation activity along  Introduction of exotic marine species into local waters the South African coast are still relatively low, and displacing local species; significant cumulative impacts are only expected if simultaneous seismic surveys take place in relatively close  Disturbance of and damage to the benthic proximity to each other and/or shortly after each other, environment; which is deemed unlikely at present.  Increase in marine traffic and vessel collision risk; Table 3 below summarises:  Vessel lighting disturbing marine fauna and birds;  The impacts assessed in the EIA;  Discharge of wastewater affecting water quality and  Their significance before and following the marine organisms; implementation of essential mitigation measures, on  Employment creation; and which the significance rating is based; and  Contribution to the national economy.  The key (non-standard essential) mitigation measures. For all potentially significant impacts, the significance of Impact significance ratings legend: the anticipated impact was rated without and with Rating +ve -ve recommended mitigation measures. These impacts are Insignificant I I presented in Table 4. Very Low VL VL The significance of potential impacts of the proposed Low L L project was determined to assist decision-makers. Medium M M Relevant observations with regard to the overall impact High H H ratings, assuming mitigation measures are effectively Very High VH VH implemented, are: The project does not have distinct construction or  The predicted marine ecology impacts, mainly operational phases. As such, the impacts discussed below associated with possible injury to or altered behaviour relate to the impacts of the seismic survey.

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Table 3: Summary of impacts Significance rating Key selected non-standard mitigation/optimisation measures Impact Without With (repeated items are only included the first time) Mitig. Mitig. POTENTIAL MARINE ECOLOGY IMPACTS Injury or behavioural I I  None changes in plankton Injury or behavioural changes in inverte- I I  None brates (excl. squid)  Implement airgun “soft-starts” of at least 20 minutes duration. Injury or behavioural VL I changes in squid  Avoid surveying during the peak squid spawning periods between early September and late December, if possible.  Do not undertake seismic survey activities within Marine Protected Areas. Injury or behavioural L I changes in fish  Undertake the survey from February to late May to avoid the key fish spawning period in spring and early summer, if possible.  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). Injury or behavioural  Record seabird incidences and behaviour. M I changes in seabirds  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.  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 Injury or behavioural of the survey are observed. M VL changes in turtles  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'.  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. Injury or behavioural  Employ onboard Independent Observer(s) / MMO(s) with experience in seabird, turtle VL I changes in seals 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.  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 for the presence of cetaceans near the survey operations as follows: Injury or behavioural  June to December: Day time: Visual observation and PAM technology and Night time changes in whales M L and periods of poor daytime visibility: PAM technology and infra-red technology; and dolphins  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.

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Significance rating Key selected non-standard mitigation/optimisation measures Impact Without With (repeated items are only included the first time) Mitig. Mitig.  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  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 Reduced catch by Inshore Fishing Association (SECIFA). VL VL demersal trawl sector  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  Notify the operators of mid-water trawl vessels of the survey timing, area and safety mid-water trawl VL VL clearance requirements prior to the commencement of the survey through the South sector African Midwater Trawling Association and Oceana Group Ltd.  Notify the operators of demersal long-line vessels of the survey timing, area and safety Reduced catch by clearance requirements prior to the commencement of the survey through the South demersal long-line VL VL Africa Hake Longline Association (SAHALLA). (hake) sector  Undertake the survey from January to March (inclusive), when fishing effort is lower. Reduced catch by  Notify the operators of demersal long-line vessels of the survey timing, area and safety demersal long-line VL VL clearance requirements prior to the commencement of the survey through the Shark (shark) sector Longline Association. Reduced catch by  Notify the operators of pelagic long-line vessels of the survey timing, area and safety large pelagic long- I I clearance requirements prior to the commencement of the survey through the South line sector Africa Tuna Longline Association (SATLA). Reduced catch by  Notify the linefish vessel operators of the survey timing, area and safety clearance traditional line-fish VL VL requirements prior to the commencement of the survey through the South African sector Marine Linefish Management Association (SAMLMA). Reduced catch by  Notify the operators of purse-seine vessels of the survey timing, area and safety small pelagic purse- VL VL clearance requirements prior to the commencement of the survey through the South seine sector African Pelagic Fishing Industry Association (SAPFIA).  Notify the operators of rock lobster vessels of the survey timing, area and safety Reduced catch by clearance requirements prior to the commencement of the survey through the South south coast rock L VL Coast Rock Lobster Association. lobster sector  Undertake the survey from June to September, when south coast rock lobster fishing effort is lower.  Notify fishermen of the survey timing, area and safety clearance requirements prior to Reduced catch by the commencement of the survey through the South African Squid Management M VL squid jig sector Industrial Association (SASMIA).  Undertake the survey from February to September when squid fishing effort is lower.  Notify DAFF of the survey timing, area and safety clearance requirements prior to the commencement of the survey. Reduced opportunity  Ensure that Daily Coastal Navigational Warnings are issued via the South African Navy for DAFF research L I Hydrographic Office (SANHO). survey  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.  Notify coastal water users, notably dive operators, of the location and schedule of the seismic survey. Disruption of coastal VL VL (tourism) activities  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.

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South African oil and gas resources. It does not fully comply 9 CONCLUSIONS AND RECOMMENDATIONS with certain social, economic and ecological planning objectives, as the seismic survey may affect fisheries and 9.1 Principal Findings can cause behavioural changes and disturbance of sensitive The potentially significant environmental impacts associated and internationally protected marine fauna, although with the proposed seismic survey considered in the S&EIR injuries and death are less likely if standard mitigation process include marine ecology and socio-economic measures are applied. Impacts can be minimised by (including fisheries and coastal tourism activities). scheduling the survey in the period from February to May. Key mitigation relates to the detection, observation and avoidance of marine fauna in the vicinity of the survey 9.3 Authorisation Opinion vessel, notification of fishing sectors of the exclusion zones This EIA Report has identified and assessed the potential associated with the survey vessel and avoidance of certain biophysical and socio-economic impacts associated with the periods that are of particular importance to certain marine proposed 3D seismic survey in the Southern Cape. fauna and/or fishing sectors. SRK believes that sufficient information is available for PASA The EIA has identified periods of particular importance to to take a decision regarding authorisation of the certain marine fauna and/or fishing sectors, during which development. seismic surveys should ideally be avoided to reduce adverse The seismic survey will result in unavoidable adverse impacts. In combination, sensitive periods occur throughout environmental impacts, although these are of relatively the year: consequently there is no single, ideal limited extent, given the limited footprint of the target area window/period to conduct the seismic survey so as to (relative to the Pletmos Basin), relatively short duration of further reduce all impacts. the survey and transient nature of the seismic survey (no Noting the particular importance and sensitivity of longer- physical infrastructure will be installed). Consequently, none lived and endangered mammals, notably cetaceans, it is of these adverse impacts are considered unacceptably recommended that the survey takes place outside of the significant and all can be managed to tolerable levels cetacean migration period. Also considering the importance through the effective implementation of the recommended of January for fish and squid spawning and squid fishing mitigation measures. sector, it is recommended that the survey is conducted in Working on the assumption that Sungu Sungu is committed the period from February to May, when impacts are largely to ensuring that the seismic survey is done to high minimised. environmental standards, achieved through implementation The impacts associated with the seismic survey, particularly of the recommended mitigation measures and ongoing if undertaken in the clearly preferable period from February monitoring of performance, SRK believes and the EIA Report to May, are considered to be acceptable. If the survey is demonstrates that through effective implementation of the undertaken outside of this period, pre-mitigation impacts stipulated mitigation measures, the adverse impacts can be are rated to be of medium to low significance. Additional reduced to levels compliant with national (and delays to the survey are likely, owing to the increased international) standards or guidelines. presence of cetaceans in the area, and significant SRK believes that the specialist studies have shown that the stakeholder concern is anticipated. seismic survey is generally acceptable. The EIA has also The seismic survey does not involve the placement of any assisted in the identification of essential mitigation physical infrastructure. As such, there is no need for measures that will mitigate the impacts associated with decommissioning or rehabilitation at the end of the seismic these components to within tolerable limits. survey, or financial provisions in this respect. In conclusion SRK is of the opinion that on purely The No-Go alternative implies no change to the status quo ‘environmental’ grounds (i.e. the project’s potential socio- and thus no additional impacts on marine ecology or economic and biophysical implications) the application as it fisheries relative to the current situation. As such, the No-Go is currently articulated can be approved. February to May alternative is preferable from an environmental and socio- are the most suitable months for the seismic survey, when economic perspective at present; however, it precludes the impacts are largely minimised and would demonstrate possible discovery and future exploitation of oil and gas compliance with best practice. resources in the Pletmos Basin, which are desired in terms of national policy. 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

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HOW YOU CAN YOU PARTICIPATE IN THE EIA PROCESS

The EIA Report can be amended based on comments received from stakeholders. Stakeholders’ comments on the EIA Report will assist PASA in making a decision regarding the application. The public is therefore urged to submit comment. The Final EIA Report will reflect comments and be submitted to PASA for approval. Once a decision is taken by authorities, this decision will be communicated to all registered IAPs.

REVIEW THE REPORT ATTEND A MEETING Copies of the complete report are available for Two Public Open Days will be held to present public review at the following: and discuss the findings of the EIA:  Knysna Public Library; Public Open Day 1:  Plettenberg Bay Public Library; Venue: Piesang Valley Community Hall  Jeffrey’s Bay Public Library; 7 Green Point Avenue  SRK’s Cape Town office; and Plettenberg Bay

 SRK’s website: www.srk.co.za – click on the Date: Wednesday 3 May 2017 ‘Recent Publications’ and then ‘Public Time: 15h00 – 18h00 Documents’ links. Public Open Day 2: IAPs are invited to comment, and/or to register on the Venue: St Francis Bay Village Hall project database. IAPs should refer to the PASA reference 2 Assissi Drive number and must provide their comments together with St Francis Bay their name, contact details (preferred method of Date: Thursday 4 May 2017 notification, e.g. email), and an indication of any direct business, financial, personal or other interest which they Time: 15h00 – 18h00 have in the application, to the contact person below, by Stakeholders can attend at any time during the 16 May 2017. specified hours.

REGISTER OR PROVIDE YOUR OPINION Register or send written comment to: Wanda Marais SRK Consulting Contact details: Tel: + 27 41 509 4809 Fax: +27 41 509 4850 Email: [email protected] P O Box 21842, Port Elizabeth, 6000, South Africa

HILL/REUT 510482_Pletmos Seismic_EIA Report_Executive Summary April 2017