Response to Rhino Oil & Gas Application for Exploration Rights in KZN
According to an environmental consultant involved in Environmental Impact Assessments (EIAs) for the oil and gas industry, once a right to explore is granted you can be pretty certain extraction will take place. Despite the various other stages of the EIA process, it is unlikely that it will be stopped later. For this reason it is imperative that we stop Rhino Oil & Gas (ROG) getting an exploration right. As Sinegugu Zukhulu so eloquently puts it “You don’t start to pay lobola if you don’t intend getting married.”
For most of us, this is the first time we are engaged in this commenting process and it is pretty daunting. Jane Weston, is also doing this with no legal or technical expertise and we recount her experience and her comments here, in the hope that you will be inspired to at least send something to SLR (consultants for Rhino) before the deadline of Monday 11 April.
Jane wrote to SLR when the Scoping Report was made public:
I went to my local library today to request the scoping report. Prior to beginning to try and read it, I note that it constitutes three full lever arch files – presumably compiled by a lawyer and in that type of language. As someone who is simply a interested and affected (I&AP) member of the public with no legal background, no technical background, and also in the interests of more rural people or anyone indeed who might perhaps have even less of the requisite education/ understanding/English expertise or English as a first language, to make an informed and educated decision, can we request :
1) an extension if necessary to the period prescribed?, or
2) a meeting with SLR in Howick or in the Midlands region for a full discussion of the report and a thrashing out of issues arising? or
3) does the 20 page KZN Executive Summary constitute, from SLR’s perspective, a comprehensive and transparent summary of the scoping report? I would be surprised if it was, even without a legal background.
Matthew Hemming of SLR, responded:
Thanks for the comments. The scoping document is voluminous, which is a direct reflection of the level of public interest in the project. The great majority of this is however supporting documentation for record purposes.
The written report is just over 300 pages with 150pg of this detailing the comments that have been raised. Thus the actual written part of the report is around 150 pages which is not unusual for a scoping report. The executive summary (available in English and isiZulu) is aimed at providing a comprehensive summary of the report contents for interested and affected parties.
The granting of time extensions in the EIA process lies with the Petroleum Agency, and requires the demonstration of ‘exceptional circumstances’. A request could be made, but in my experience would be unlikely. Formal meetings to discuss the contents of scoping reports are not part of a typical EIA process and are not planned. There will be further meetings in the following phase where the findings of the EIA work will be discussed.
Jane’s final submission to SLR:
Good day Mr Hemming,
As a general I&AP seeking to develop informed and reasonable opinions on the project, I herewith present my 44 random questions without prejudice or fear, motivated by a citizen’s concern for many aspects that are under threat.
I have tried my best to read the report thoroughly but have run out of time. I apologise for my lack of expertise in legal, procedural or technical areas and my possible misunderstanding of certain issues, but I am probably representative of many others who might struggle with the extent of the report and procedures, and offering comment within the limited time available. Some of my comments/questions no doubt will fall outside the scope of this EIA which makes me think this is a waste of time.
As an observation, every time you state that the questions are beyond the scope of this EIA, that not much will happen in phase 1, that little disturbance can be expected, that only .0001% land will be affected, it simply reinforces the perception that future phases will be the exact opposite, will be hugely damaging, wide ranging and have devastating effects on human livelihoods let alone fauna and flora.
I quote from the Report, and the questions I raise are in bold.
Yours sincerely, JS Weston
- I understand that ‘The assessment of possible further exploration or future production is outside of the scope of this Scoping and EIA process’ ; ‘It is clear that the EIA process will not be able to resolve such objections’ ; ‘These issues and concerns are documented, but will not be responded to as they are made in regard to further exploration work or future production activities which have not been proposed by Rhino Oil and Gas for this application…’.; ‘The primary intent was to inform landowners and other I&APs of the proposed exploration right application, in sufficient detail, in order that they may contribute meaningfully to the identification of impacts and alternatives during the Scoping phase’
Question – Would you agree that ‘contribute meaningfully’ has not been achieved to the satisfaction of the IAP’s and general public? It is disingenuous to suggest that ‘future activities have not been proposed’ and that you are unable to address the issues that those future activities point to. Refer Q5.
- ‘Public participation is an ongoing process and will continue throughout the EIA. Comments from I&APs will continue to be received and documented for the duration of the EIA process.’
Question – Am I right in thinking most of those comments/questions will only be dealt with in the EIA which occurs after year 3 of the proposed process? ie once invasive work begins.
- ‘The reasons for the public opposition are varied and in many cases are not explicitly stated or articulated in the submissions. SLR does not find it possible to adequately explain the nuances/reasons/motivation for the opposition, as much of this is deeply personal to each I&AP’
Question – As the independent EAP responsible for undertaking the required environmental assessment and conducting the public participation process, are you not obliged to understand comments fully in order to effectively conduct the public participation process ? Observation: We can’t have been reading the same comments.
- Question – Would SLR employ any of the highly knowledgeable/competent/informed/eminently qualified experts, organisations who have contributed Comments and Objections and could therefore be seen as more impartial, transparent and independent contributors to the EIA in the spirit of your statement that ‘The process involves an open, participatory approach to ensure that all impacts are identified and that decision-making takes place in an informed, transparent and accountable manner’.
- Question- Would you agree, that based on the following quotes, it is plainly clear that this project IS planned to continue way beyond this phase, regardless of the Public Participation Process and your objective is to enable this to happen and mitigate anything that might prove an obstacle?
You say “approval is not being sought for any work to determine the commercial viability of any such resource’ yet this is in direct contradiction to ROG’s statement and the government’s stated interest as per ‘ultimate goal for the overall project is to extract hydrocarbons in a commercially viable manner.’ and the comment by ROG ‘very little will be accomplished in the 3 year ‘no drill no invasive’ period’ and ‘It is noted that the only reliable way to determine whether the identified formations contain hydrocarbons is to undertake exploration well drilling (DTI, 2001) and ‘The draft EMpr will provide recommendations on how to select, establish, operate, maintain and close the activities and associated infrastructure through all relevant phases of the project life.’
Question- so will all the comments and objections then be dealt with in the EMPr if not the EIA in phase 1?
- ROG’s quote that they will ‘undertake Least amount of work and least cost and this phase is unlikely to produce any real and worthwhile info’ and ‘It is therefore only possible to determine the properties where on-the-ground activities (e.g. core drilling and seismic surveys) may take place once the initial phases have been undertaken. These initial phases can only be undertaken once an exploration right is granted’
Question- Would you agree this tends to point to the ‘rubber stamping’ of the ‘future exploration activities’ as someone mentioned?
- P3 ‘The initial exploration work programme is restricted to various non-invasive and remote techniques’ – yet later on you state ‘The primary mitigation applied to the early-phase exploration would be to use non-invasive, remote sensing techniques as much as possible in order to refine the information on where to conduct field exploration.’
Question- Would you agree that ‘restricted’ and ‘as much as possible’ do not have the same meaning and ‘as much as possible’ could leave an opening for more invasive means to be utilised?
- ‘Section 10 of the MPRDA makes provision for the Regional Mining Development and Environmental Committee (REMDEC) to consider and advise the Minister of Mineral Resources on objections received in respect of applications for permits or rights. Thus PASA will send all objections received in respect of the current application to the relevant REMDEC for consideration before a decision to grant or refuse the exploration right is made by the Minister”
Question – So there is no direct engagement available to IAPs with PASA, as the agency of DMR in a “process providing for further engagement with I&APs and in-depth assessment of the associated issues.’ ?
Question – Am I right in thinking any of these bodies can completely reject/ignore/overrule, if they wish and without explanation, the following ; IAP comments and objections ; your EIA and its “role of … to identify all such constraints and restrict or prohibit exploration activities through documented management commitments’; the EMPr and SLR’s authority to enforce/ensure compliance ?
As per their website ‘Rhino Resources, Ltd. is committed to work cooperatively and responsibly with local communities and our partners in our host countries, and perform our obligations in a social, environmental, and ethical manner for all stake holders over a sustained period of time to obtain real results and lasting change’.
Question – Will IAPs ever have a chance to engage with the directors of Rhino Resources?
- ‘This work is aimed at identifying and defining the extent of ‘sweet spots’ with high potential for reserves of oil and / or gas, as well as whether or not the size of the resource warrants further study and drilling.. At the end of this stage the non-prospective areas would typically be relinquished by the project.’
Question – So who will be tasked with monitoring that only 10 core holes will be drilled and that ROG’s assurances that they will keep to that?
Question – Once ‘relinquished’ does that mean forever? What is the legal implication of this word?
Question – Would you agree that an independent monitor/observer must be appointed and allowed access to the areas in which they propose to work do you agree?
- ‘exploration right application area is extensive and it is not considered feasible nor necessary to undertake surveys of every aspect of the area in order to obtain the regional understanding that is required’ yet later you state ‘Each locality would be subject to an environmental site assessment and approval from PASA to ensure that the activity is not being placed at a sensitive site.’
Question – Sounds a bit contradictory to me?
- “There will be no significant changes to the project description or surrounding environment between the completion of the scoping and EIA process and implementation of the proposed project that could substantially influence findings, recommendations with respect to mitigation and management, etc.”
Question – So does this mean that the EIA is a done deal ?
- Your report is replete with typos and spelling errors which is not indicative of care and attention to detail nor the professional standard one might expect from a company such as yours.
‘The EIA is being ‘consucted’ in terms of the guidance from PASA’
Question – So you are not independently or impartially producing this EIA?
- While I understand your claim of being ‘independent and having no vested interest” are you by law then legally responsible should any aspect of your EIA reports lead to damage or injury to any of the parties, land owners, land inhabitants or by virtue of any omission, negligence or professional lack of understanding of the national and international best practice ?
- Rhino Resources website suggests they wish to be transparent and ethical in their dealings so will the whole financial aspect of this project be transparent?
Question- Would SLR agree that the entire financial aspect of this project and the compensation/insurance issues that will arise, requires a very specific financial/ expertise that would lie beyond the scope of your company’s current expertise for either this or the next phases of the project and EIAs?
Question – Will you be employing independent financial assessors that represent the interests of not just ROG, RR or SLR?
- Apropos the above and quoting Gaetane Le Grange Comments section ‘The pre-cautionary principle states that, if one does not understand the impacts fully, they should not go ahead with the project. The ‘polluter pays’ principle states that, the one who causes pollution is responsible to mitigating it. Both these principles apply in this process’
It is therefore concerning that when another lady asked at one of the meetings, ‘what Rhino’s policies were about clean up after accidental contamination. I was told Rhino had none”
You state ‘It is in the interest of Rhino to adopt an all-encompassing definition of rehabilitation.’ “Rehabilitation would be undertaken to re-establish pre-exploration land use. The process of managing the impacts and rehabilitating the exploration sites would be conducted in terms of an EMPr approved by the PASA”.
‘This quantum must be made available by Rhino Oil and Gas to PASA as security for the completion of rehabilitation should Rhino Oil and Gas fail to do so. PASA in consultation with other relevant authorities would determine the use and allocation of this money for rehabilitation. The financial provision that needs to be made is not limited to the land on which the exploration would be undertaken, but would provide for rehabilitation of damages from exploration. The quantum of the required financial provision would be determined through the EIA process. The amount and the method of providing the provision would be detailed in the EIA report.’
Question – As I understand it, ROG are not liable in the long term and have no track record to suggest they are a financially sound outfit? If they go ‘belly up’ many people will be left in a difficult position and from what I understand PASA makes the decisions about rehabilitation and how much and to who and not the ‘polluter”?
Question – An independent overseer must surely be critical to monitor how monies are allocated and how to ensure that procedure remains legitimate?
Question – Is there a specific time frame in which the Minister/PASA/MPRDA should/can issue a ‘closure certification’ to the holder ?
Question – How is the landowner or other affected party protected in this process, if the time frame can expire or proscribe?
Question – Will the EMPr specify responsibility in the long term?
Question – What happens if ROG/RR no longer operating, have passed on the liability to someone else who refuses to honour it – liability is of no legal consequence surely if company no longer around
- ‘Prior to the early-phase exploration (as proposed) being concluded they are therefore not able to provide any information on what the future may bring with regards the extraction of hydrocarbons’
Question – With ROG/RR’s claims of expertise as ‘the operator for the proposed project” locally and internationally and the vast information from 60 odd years of fracking overseas (they did all the base work, research, and path finding) would you agree it is foolhardy for the applicants not to do more sums on operational costs/productivity before they launch such explorations? No forward projections of any kind ? but they request that we respect their expertise?
Question – Do you find that short sighted in the extreme?
Comment from I&AP: Viability: Any proposed fracking project must prove its viability on the basis of an Energy Return On Energy Invested (EROEI) study, also known as, Net Energy Return (NER)
Q Will you be using the EROEI/NER method in your EIA
- ‘The aim will be to identify key features of the groundwater resource and to define which regions may be incompatible with the proposed exploration activities related to the groundwater resources. Pxii’
“Water required for the operation of the drilling rig as well as potable water would be obtained from an available source and in compliance with legislation’
Given what we know from international experience and the effects on water supply/quality (and the negative effects on water are not different in SA from any other country, surely) and that this is a small area comparatively with key water resources in a dry country ….
Question – Surely your expertise as an environmental scientist will ensure that when it comes to water you will find no mitigating reasons, no loopholes, nothing to suggest that this country, this region, we citizens can afford any water let alone the humongous quantities we hear are required, using that ‘reassuring’ word ‘only’ 100 000 litres per hole per single drill multiplied by thousands of drill episodes? You state somewhat differently ‘For an average of 20 days of drilling, the total water use per hole is likely to be less than ~100 000 L’.
Question – Would you agree, the inability to be certain around the quantity of water to be used is surely unacceptable, renders the EIA unreliable in this instance and open to abuse ?
Recent American information states ‘horizontal portions of wells have grown longer, while the number of “stages,” or sections of a well that are hydraulically fractured, has increased: Both of these factors drive water use up such that they are bringing in new laws and regulations.”
Some citizens have meters and pay good money for every drop we use, listen obediently to urges to be waterwise, reduce consumption, shower rather than bath – others rely on boreholes and rivers and walk many kilometers to find suitable quantities and quality of water.
Question – So how does ROG get it right to use, unsupervised – up to or including maybe, perhaps, who knows 100 000+++++ litres for one drilling of one hole (thumbsuck and underreported) or your claim of 20 days worth (also surely thumbsucked and underreported) or whatever is the SA equivalent they are allowed to use as per water volumes permitted by the General Authorisation (No. 1191 in the Government Gazette No. 26187 published on 26 March 2004)?
- ‘Rhino Oil and Gas would need to be aware of such constraints for their planning as the lack of water could influence where exploration activities are undertaken. ‘‘The aim will be to identify features of the resource that may be sensitive to contamination and which should be avoided. ‘
Question – How will they monitor/measure their volume usage and who will check up on them?
‘No activities are being proposed that trigger the need for a Water Use Licence, although certain water uses would need to be assessed once the volumes and localities are known’ –
Question – Would you would agree this is so loose an arrangement, it will be hard, if not impossible to monitor or control on their part and is likely to be abused, negligently, unknowingly, or carelessly and without regard ?
- Rhino Resources claim on their website: on their Corporate Responsibility page they emphasise ‘the benefit of enhanced prosperity for African host countries and local communities including ‘ensuring access to clean water”
Question – Will they commit to showing us specifically how they will achieve this through the proposed project ? Will they set out what the costs are to them, what shareholders can expect, the government’s percentage, the landowners benefit, rural communities that live in exploration areas, so that figures can do the real talking?
Question – Would you agree ‘fracking’ and ‘clean water’ are contradictions in terms?
- ‘Hydraulic fracturing could be one of the potential techniques for gas production.’
Question- Why does the report not mention green or eco-friendly methods ?
Question – Does SLR have the up to date expertise to undertake investigating any other techniques that may be more green or environmentally friendly (ie no water drilling, desalinated water).
Question – Do you agree that if the process is an expensive one, the applicants will go for the cheapest methods so very likely will throw out any eco-friendly/green options? And cheap usually means more damaging, right?
Question – Who has the skills locally to undertake the many potential techniques for gas production?
- ‘The outcome will be to define which habitats for fauna may be incompatible with the proposed exploration techniques and to determine exclusion criteria’
Question – Will an independent observer have access to the areas that ROG will operate in to ensure those criteria are followed, especially as fauna generally have no concept of ‘exclusion criteria”?
- ‘Guidance on how to manage chance finds of heritage resources will also be detailed.’
Question – What about unmarked graves or war graves of unidentified soldiers since this is a historically significant area? There is an extensive legal governmental procedure to be followed when any unmarked grave is discovered. Apparently it Involves advertising for family members or descendants, disinterrment, reinterrment at a proper cemetery, marking of the new grave. No doubt the ancestors, where applicable, will need to be recognised and the requisite cultural procedures and rites will need to be honoured and paid for.
If the permission is given to the drilling company by the landowner and a neighbour of the landowner is negatively impacted, affected, something is damaged or some health issue arises due to activities on neighbour’s ground, who gets sued – the guys doing the drilling that caused the impacts or the guy who gave the permission for the damage to occur ?
- The impact on the local economy will be further investigated and assessed in the EIA. An economic specialist may be consulted for input.’ Pxvi
Question – Considering this is one of the positives touted as the great benefit to all of us, then may should be must?
Past history does not bear out that the many will benefit and that deals made will produce the goods to the advantage of SA and not just for a few vested interest parties.
The idea of employment is promoted and a figure of 700 000 jobs is quoted in various sources, including your report if I’m not mistaken, and ROG commit to training and skills transfer, but your report contradicts this
‘However, since exploration is highly technical and requires specialised equipment and crews, job opportunities for local communities would be very limited. The small number people required and very short duration of each of the proposed exploration operations further limits opportunities. A staff of approximately five persons would operate a drill rig, while seismic survey teams would consist on between 15 and 25 persons.’
Yet elsewhere you state ‘In addition, the proposed project would indirectly contribute to economic growth in the national, local and regional economies by strengthening the national economy and because the increase in the number of income earning people has a multiplying effect on the trade of other goods and services in other sectors.’
Question – So you seem to contradict yourself regarding the potential employment opportunities especially for the majority unskilled workforce?
Question – How will this situation change once phase 2 and 3 get going to assure the unemployed that the promise of jobs is real?
- p60 Objective of EIA Scoping report ‘To identify suitable measures to avoid, manage or mitigate identified impacts and to determine the extent of residual risks that require management and monitoring. The outcome would be to determine practicable mitigation measures to reduce any potential negative impacts.’
Question – Why do you focus on mitigation rather than prohibition?
- SLR uses an assessment methodology which considers:…… The significance of environmental impacts will be rated before and after the implementation of mitigation measures. These measures may be planned or additional measures that may arise from the impact assessment and specialist input. Pxv111
Question – Without baselines studies how can one rate the ‘before’ based on outdated reports and desktop surveys?
- ‘The environmental management programme will detail restrictions required to ensure that no unauthorised activities are undertaken during the proposed exploration’
Question – Who will be tasked to supervise this and will they be independent of vested interest ie who pays them?
- ‘Full details of the water volumes, types of drilling fluids and the water management will be provided in the EIA report’.
Question – Since only some of the drilling fluids are recycled – will your EIA identify what happens to the rest, what quantities are involved, how waste water management will be handled or will it just be vague descriptions.
- All general and hazardous waste generated at the drilling site would be separated and stored in containers, before being removed from site and disposed at an appropriate waste disposal facility.
Question – Does such expertise exist in SA and if so will they be named? Where will the waste disposal facility be situated and who will ensure dumping does not occur?
- The expected dispersed nature of petroleum resources is such that a reasonably large area is required initially in order to secure a resource that may be economically viable.
Question – Do you agree in future phases, beyond the scope of the current EIA, that the reasonable person would expect this to mean major disturbance, habitat destruction, for the sake of a small quantity of difficult to extract gas, requiring untold numbers of core holes ranging across all kinds of terrain, frequent new drilling in new places to replace old ones, huge waste issues, extensive contamination issues?
- Rhino was granted the opportunity to apply for the proposed Exploration Right based on experience. In terms of the MPRDA, an exploration right can only be granted if, inter alia, the applicant has access to financial resources and has the technical ability to conduct the proposed exploration operation optimally in accordance with the exploration work programme.
Question – What technical ability did the two guys at ROG claim to get the exploration right granted?
Will the financial resources be held in a separate account that is handled by an independent body with due checks and balances to ensure said account not emptied by interested parties? Will this be as transparent as RR suggests is their company ethos?
- Geological data is data that Rhino would use to determine both the financial and technical feasibility of the resource. If shared publicly, it can disadvantage the competitive advantage of rhino
Question – So were there any other companies bidding/negotiating for the exploration application? If not, it won’t disadvantage ROG surely?
- SLR will assess the impacts of the proposed early-phase exploration work programme.
It is not possible to provide an informed assessment of potential future impacts where the proponent has no idea of the project plan, the methodology or the locality. The scope of the current EIA is therefore linked and limited to the early-phase exploration work programme.
Question – They have no idea of the project plan??? Is this another typo?
- ‘Rhino Oil & Gas indicated to SLR that it wil ensure that all of its activities are undertaken in a lawful and environmentally responsible manner ‘
Question – Who will oversee them and ensure they adhere to the less than 50ha and less than 0.0001% of the surface Section 188.8.131.52? They may claim this but unless the techniques and procedures are in place with people who know what they are doing this statement can only be wishful thinking at best and dangerous at worst, don’t you think?.
36 The potential impact on water resources is discussed separately below (see Section 5.4.8 and Error! eference source not found.). ??? Meaning?
37 ‘Other mitigation to minimise the impact on groundwater resources that will be considered for inclusion in the EMPr include:
- Monitoring of groundwater (level and quality) in active water boreholes in close proximity to exploration boreholes must be considered.
Question – This surely should be mandatory not just ‘considered”? Especially as there will be some drilling. This surely is leaving holes the size of a house for any future legal action to fall through?
- ‘ Fluids are designed to not move far from the drilling hole unless very poor formations or large cracks are encountered; ‘
Question – Who will know this before the drilling starts? Sounds very flakey considering technical excellence claimed?
- Although in almost all cases exploration sites/routes would be located where access is available, the seismic survey lines may be required to cross watercourses. Any activity that impedes or diverts the flow of water in, or alters the bed, banks, course or characteristics of a watercourse, requires Water Use Authorisation in terms of the NWA
Question – when will anyone know this and be obliged to obtain WUA? Who will be doing due diligence?
- As such a change in land value is highly unlikely for early phase exploration
Question – Would you agree another key issue which is being ignored and therefore prevents meaningful engagement by IAP’s before the damage is done and the process can’t be stopped?
- ‘The current EIA is aligned to the early-phase exploration work programme as proposed by Rhino Oil and Gas. The potential impacts of further detailed exploration and future production activities would not be assessed in the EIA process.’
Further to this, Rhino Oil and Gas maintain that due to the current informiaton and the nature of exploration they cannot have details at this stage on what the resource is, where it it located geographically or geologically, or how it might be extracted. As the EAP it would simply be speculation to undertake an environmental impact assessment of future activities for which no defined details are known’
Question – Despite RR claims that they have identified resources in this region?
‘I&APs are advised that the responsibility for the assessment of impacts of any future exploration or production activities would fall to the future EIA (or environmental authorisation amendment) process which is required by legislation to inform the environemtal authorisation required as part of a mineral right. This would include a further public participation process and in-depth assessment (including specialist studies) of all project-related activities / issues. The assessment would be based on the known details of the work as proposed by the applicant. It is also expected that if/when this phases commences that the Karoo SEA for Shale Gas will be complete and will provide a sound basis on which to undertake an assessment of future exploration work.’
Question – The applicant says ‘very little by way of information will be forthcoming in this phase’ so what known details do they allude to?
Question – Why not wait for the Karoo SEA to be completed so there is, as you say, a ‘sound basis’ on which to work, which ROG appears to not have in any shape or form with this giant project?
- No critically endangered ecosystems are located within the proposed exploration area (Mucina and Rutherford, 2006).
Question – Considering the challenges to our natural environment and based on the outdated information you seem to be relying on, can this still be the case? Do we have to get to the point of extinction before we take notice and give it exclusion?
- Question – Will the EIA address the issue of below ground horizontal drilling and the risks inherent? If not, why not, given that it is highly controversial?
- ‘The preliminary assessment ratings provided in this table are for the unmitigated scenario only which assumes that limited consideration is given to the prevention or reduction of environmental and social impacts. In most cases the alternative would be the mitigation’
Question – Does this mean nothing will be allowed to stand in the way?
Jane concludes: If those of us who have done some homework are still unsure or bamboozled by the legalese and technical ‘smoke and mirrors’, then what hope those who are not proficient in English? Even if it is produced in 11 official languages, and especially when those languages don’t have the words – a member of the audience at one of the meetings, did provide one for ‘well’ but for ‘anthropogenic’, ‘pollutant migration’, ‘shallow aquifers’??? By the time we have documents translated and time to be fairly and transparently informed of what the real story is behind this company and their sponsors, I fear permissions will be a distant memory.
Everyone who can should comment – even a few lines will do. What is the issue you are most concerned about? Seismic Surveys? Water Contamination? Community disruption? Loss of Sense of Place and Tourism potential? Damage to Agriculture? Whatever you are worried about, you can be sure there are hundreds of others who are too, but may not be able to express their fears. Just pick the thing that worries you the most and write a note to SLR today!
If you would like a copy of the Frack Free SA comments to SLR, that will be submitted on Monday 11 April, please email firstname.lastname@example.org