02 Eassy Submarine Cable

IMPACT ASSESSMENT CASE STUDIES FROM SOUTHERN AFRICA

Compiled by Paul Scherzer SAIEA E&D Consulting Services Client: Telkom SA Southern African Institute for Environmental Assessment ... working for a better Africa ROUTING OF THE EASSy SUBMARINE CABLE, SOUTH AFRICA Compiled by Paul Scherzer E&D Consulting Services Client: Telkom SA ROUTING OF THE EASSy SUBMARINE CABLE, SOUTH AFRICA

Aims of the Project Brief description of the development and alternatives considered

Telkom SA operates existing submarine fibre- Submarine telecommunication cables form a vital optic telecommunication cables in South African part of the global communications network. Fibre waters from two landing locations, one on the optic cables are essentially tiny glass fibres which west coast and the other at Mtunzini on the east. transmit digital pulses converted by computers at The South Africa Far East (SAFE) submarine cable was landed at Mtunzini in 2001. The existing cable station and shore-based infrastructure at Mtunzini had capacity for an additional cable. Telkom SA proposed to land another cable, the East Africa Submarine System telecommunications cable (EASSy), on the main beach of Mtunzini.

The aim of the proposed EASSy cable was to Figure 2: Illustration of cables enhance telecommunication links along the east and increasing levels of armouring coast of Africa, as this region relies exclusively on satellite which is expensive and limited in capacity. each end of the cable. A typical lightweight cable has a 17 mm outer diameter and comprises a welded steel tube housing multiple fibre pairs in a stress-free environment. In order to protect the cable, depending on the level of risk, the number and diameter of armour wires surrounding the cable is increased, with a high strength double armoured cable having an outer diameter of Figure 1: Route of the proposed EASSy cable approximately 45 mm (Figure 2). down the east coast of Africa.

Brief description of the development and alternatives considered

The routing and laying of a submarine mountain slopes and deep trenches below the Importantly, one survey ship is contracted to telecommunication cable is preceded by detailed ocean, areas of heavy shipping and rocky eroding undertake the survey for the entire cable and all planning involving market capacity and marine beaches as landing points. the landing locations. Thus, due to the distances cable routes, as well as negotiation between and costs involved, the survey is undertaken various international telecommunication service The greatest danger to communication cables is according to a programme that is relatively providers regarding financial contributions and from bottom contact fishing methods performed inflexible in terms of accommodating last minute market share. In order to select the optimum route by trawlers. For this reason Telkom stipulates a changes or repeating parts of the survey to for a submarine cable a range of marine charts, no trawling or anchoring zone for one nautical consider other locally proposed alternatives. regional bathymetric data, seabed topography and mile on either side of their submarine cables. geology sources are consulted. Information must Due to the fact that Telkom had an existing land- also be gathered from relevant government An international cable company is appointed to based cable station at Mtunzini with spare departments, telecommunication companies and undertake the planning and implementation of the capacity, alternative landing sites were not other groups such as marine oil and gas companies. entire cable. Once initial desktop routes have been considered for the proposed EASSy cable. planned a detailed marine survey is undertaken, However, one of the key stakeholder groups which Due to the cost of laying and repairing cables at particularly in shallower waters (less than 1,000 objected to the laying of the initial SAFE cable sea, route planning considers cable safety and m deep) where the cable approaches the landing at Mtunzini was the prawn trawling industry aims to avoid, among other aspects, steep station. The purpose of the survey is to optimise operating out of Durban. The SAFE cable the position and laying of the cable traversed both the in-shore and off-shore trawling to avoid high risk areas and to grounds and for various reasons at the time an finalise the design and protection alternative alignment to miss these trawling required for the cable. A survey is grounds was not feasible. A legal dispute between then taken of an area approximately the Prawn TrawlerÕs Association and Telkom 1 km wide along the identified occurred after the environmental authorisation route, and thereafter the final cable process and laying of the SAFE cable. position is optimised within this surveyed band. Figure 3: Landing of the SAFE cable at Mtunzini

Environmental setting

The KwaZulu-Natal prawn trawl fishery consists prawn stocks found on the Thukela Banks, as this grounds. The prawn species targeted on the of two components: an inshore fishery, referred species is dependent on estuaries for their nursery offshore fishing grounds are species which are to as the Thukela Banks, and an offshore fishery not dependent on estuarine habitats during their (Figure 4). Trawlers can fish from March to lifecycle and, thus, had not been affected by the August on the Thukela Banks and year round on closure of St Lucia. the offshore grounds. Different species are caught at these respective grounds. An important socio-economic impact was that the existing trawling companies were concerned that Importantly there are few areas off the South any additional loss of trawling grounds would African coast suitable for shallow water penaeid further reduce the grounds and catches and, thus, prawn trawling due to the very narrow continental the economic viability of the trawling industry. shelf, particularly in the sub-tropical areas of northern KwaZulu-Natal which are the only areas There are only specific areas off the KwaZulu- warm enough to support a breeding population. Natal coast which are suitable for prawn trawling. The Thukela Banks fishing grounds support the Apart from the climatic conditions and sea-floor southernmost commercial prawn fishery in the conditions suitable for prawns, trawling needs to western Indian Ocean. occur in areas where there are no reefs which can snag fishing gear, and in areas large enough to Fishing rights had been allocated from 2006 to make it economically and practically viable to 2013 and were held by four fishing companies. trawl. It is not practical for trawlers to simply lift However, general opinion was that the trawling their nets over an obstacle, drop them again and industry was struggling to remain economically continue. So the trawlers will not operate in an competitive due to reduced catches as a result of area that is too small to obtain a reasonable catch the closure of the St Lucia estuary mouth and in one trawl. cheap imports. The closure of the St Lucia estuary mouth was considered to be having a significant Figure 4: Prawn trawling grounds For these reasons the trawl grounds, particularly negative impact upon the shallow water penaeid off KwaZulu-Natal the Thukela Banks, were identified as an

Environmental setting EIA process followed

environmental and economic resource which, The EIA process went through a Scoping Phase During the Scoping Phase, meetings were held regardless of current catches and cheaper imports, followed by an Impact Assessment Phase. with representatives of trawling companies to remains an important resource for conservation. discuss the proposed cable route. Various concerns Thus, whilst the actual size and operation of a were raised that the cable would further dissect submarine cable has practically no impact on the Scoping Phase public participation the Thukela Bank fishing grounds. Representatives actual prawns, the resource would be impacted if provided specific coordinates of the fishing the cable route resulted in the grounds being From the outset, the client was concerned that grounds. These positions were communicated to divided up into sections too small to viably trawl. appeals or legal disputes from the trawling the client who in turn requested the international industry would either delay environmental cable route team to consider an alternative route. authorisation or project implementation. The An alternative cable alignment was considered process was therefore designed to ensure that the and proposed. trawling industry was provided with maximum opportunity to comment and participate, and that off-shore cable route alternatives could be Specialist study considered. In order to ensure that the best cable route alternative could be selected, the The Oceanographic Research Institute was environmental consultant ensured that the process appointed to undertake a specialist study focusing of stakeholder consultation would align with the on the impacts of different cable routes upon the programme of the international cable route team trawling grounds and industry. The data used was who were planning the routes and the marine the most accurate data available and consisted of survey. The consultant was well aware that once 19,943 trawl deployments and catches between the marine survey was undertaken, no other 2000-2006. This data had been recorded by the offshore alignments would be considered due to trawlers as per the requirements of their licences. the technical planning requirements and costs associated with a marine survey. The specialist study focussed on the potential loss of trawling grounds on both the Thukela Banks and offshore grounds for the original proposed

EIA process followed

alignment and for the proposed realigned alternative (Figure 5). As both still impacted the trawling grounds an optimum route was identified that would have practically no impact upon the trawling grounds. In addition, the cumulative impacts of the existing SAFE cable, another submarine cable being planned by a separate telecommunications company, and the proposed EASSy cable, was investigated.

In all calculations of trawl grounds and proportions of the total catch likely to be lost, the trawling industry was given the benefit of the doubt. For instance, delineation of the extent of the grounds and estimates of the minimum area they required for uninterrupted trawling were done conservatively in their favour.

The specialist study was also tasked to do a retrospective assessment of the impact of the existing SAFE cable, to verify the extent to which that cable had actually impacted the industry. The number of trawl drops and size of catches made within the 1 nautical mile exclusion zone prior to laying the cable and after the cable was laid, were calculated. Figure 5: Preferred and alternative EASSy cable alignments

EIA process followed Main environmental impacts & issues

Public participation during the Impact Assess- The issues relating to the loss of trawling grounds this part of the grounds in comparison to other ment and impact upon the industry were complex and parts of the trawl grounds. varied. For this reason two sections were A key stakeholder workshop was held to which specifically included in the report: one, highlight- ¥ Other factors such as current strength, skipper representatives from all the trawling companies ing the assumptions and limitations made during skill and crew working and rest times also were invited, regardless of whether they had the assessment, and the other highlighting the play a role in determining fishing locations recently been trawling or not. The aim of this difficulties associated with an accurate assessment. and efforts. workshop was to provide the trawling industry These difficulties related to interpre-ting the data with an opportunity to discuss the draft specialist and findings in the light of other unquantifiable After careful consideration of the findings it was findings and proposed cable route alignments. factors, such as: apparent that if trawlers continued to operate over Various perspectives and issues were raised during and around the initial cable route proposed, as the workshop. The environmental consultant and had occurred with the SAFE cable, there would specialist then undertook to further investigate ¥ The importance of the inshore Thukela Banks be little impact upon the industry or the economic and clarify the additional points, and produced a fishing grounds relative to the rest of the viability of the trawling grounds. However, when summary report for further comment by the fishing grounds, and the influence of the applying a applying a risk-averse and cautious trawling industry. closure of the St Lucia estuary mouth on approach from both technical and environmental catches on these grounds. perspectives, it was preferable that trawling did These findings were then incorporated into the not occur over the cable and that the cable route draft Impact Assessment Report, which was ¥ The influence of cheaper imports of the same selected should minimize its impact on the distributed for public comment. Certain prawn species on fishing effort on the trawling grounds. representatives from the trawling industry took Thukela Banks. the opportunity to comment again. This feedback Yet, a range of other factors still needed to be was responded to and both the comments and ¥ The licensed trawling periods on the Thukela taken into account such as the findings of the responses were incorporated into the Final Impact Banks had been reduced over the period for final bathymetric survey, cable protection and Assessment Report. which data was available, from 12 months to length, feasible cable angles and turnsetc. which only six months of the year. This influenced influence the cost and risks of different cable the relative contribution of the catches from routes. These factors would influence the final

Main environmental impacts & issues Decision making process

alignment being investigated by the During the process the client, Telkom SA, as well international cable team. For this reason the as the international cable team, were open and impact assessment report identified and willing to revise alternatives in order to minimise proposed a wide corridor within which the cable environmental impacts. The impact assessment would have minimal impact on the trawling did not recommend either the first or second grounds (Figure 6). The aim of the corridor desktop alternative identified by the client and was to allow the international marine working proposed a corridor within which the client was group to optimise the final alignment with willing to survey and further plan the cable route. respect to reef crossings, cost and other technical factors, while still avoiding the The specialists were required to review the trawling grounds. sections of the draft Impact Report dealing with their findings and the draft Impact Report was then peer reviewed by a registered Environmen- tal Assessment Practitioner in another company. The final Impact Report received a positive Record of Decision from the authorities, authorising that the cable be laid within the proposed corridor. No formal appeals were submitted by stakeholders.

During the decision-making process the international marine working group surveyed a final alignment for the cable that remained within the proposed corridor, even bending north to miss the extremities of the inshore trawling grounds. At the time of writing the cable was still to be laid. Figure 6: Optimum cable corridor

Main elements of excellence in this EIA Lessons learnt

The clientÕs recognition of the potential value of benefit of doubt going towards the environment. For an Environmental Impact Assessment to add the environmental assessment process in Furthermore, in assessing these impacts, the report value to a project, the key environmental issues, optimising the project and reducing the risk of did not profess to have neatly quantified the impacts and risks need to be identified and delays and additional costs. Telkom was willing significance, but highlighted the reality that there investigated in time so that they can influence to work with the assessment team to investigate were many variables and uncertainties that made technical planning and decisions. If projects are and consider alternatives that would minimise impacts extremely difficult to quantify. not timed and coordinated correctly, the technical negative impacts, and had an approach with planning process may proceed without affected stakeholders that sought to identify win- All the assumptions and uncertainties were clearly environmental input, reducing the EIA to just win solutions. highlighted, and a retrospective assessment of the another administrative requirement that the client impact of the existing cable helped to guide must obtain. The environmental consultantÕs understanding of interpretation of the data. In the end a cautious the technical planning process enabled the EIA approach was adopted. It proposed an alternative The more contentious and difficult an issue is to process to be optimally aligned with it. which minimised current socio-economic impacts assess, the more careful the consideration of all Consequently the environmental findings were and the long-term loss of a potential resource, factors must be, and the more stakeholder provided in me to influence technical decisions. while still providing the technical team with participation is required. Importantly, this alignment would not have been enough leeway to optimise design and cost factors. possible had the client gone ahead with the An Impact Assessment Report should explain how technical planning process prior to appointing the The key affected stakeholders were involved the findings were interpreted, what assumptions environmental consultant. throughout and were provided with the opportunity were made, what uncertainties were identified, to discuss findings and interpretations. They and how the final recommendation was influenced Careful and detailed use of accurate specialist requested the assessment team to investigate by these factors. This allows the thinking and data made it possible to quantify potential impacts. further and clarify parts of the specialist findings, interpretation behind the assessment to be Importantly, the assessment separated the potential which helped to improve confidence in the results. understood by stakeholders. socio-economic impact on the currently licensed trawlers from the potential loss of future economic resources which the trawling grounds represented. The data were interpreted conservativelywith the www.saiea.com