Karoo & Us Too

While it seems to most reasonable people that fracking absolutely should not take place in South Africa, the juggernaut keeps rolling.  In the Karoo, TKAG (Treasure Karoo Action Group) managed to slow the process down a little, by calling for a full Strategic Environmental Assessment or SEA as it is known.  This was conducted by a reputable group of experts and cost millions of rands. This week comments (from the public and interested parties) on the draft report http://seasgd.csir.co.za/scientific-assessment-chapters/ are due, however, the Endangered Wildlife Trust (EWT) managed to get the deadline deferred for a week.

FFSA volunteer, Judy Bell has read parts of the 18 Chapter document and has some serious concerns that she feels we need to ensure are included in the Environmental Impact Reports that are to be compiled by SLR and EIMS Consulting for the Rhino, Sungu Sungu and Motuoane Applications in KZN, Eastern Cape, Free State, Mpumalanga, Gauteng and North West, which sounds almost like the rest of the country!

All quotes from the SEA documentation in grey text for ease of identification – bold is our emphasis. Bullet points are our questions to the Environmental Assessment Practitioners (EAPs).

Unconventional gas reserves may exist in other areas of the South African onshore and offshore territory, and would need separate consideration if their development was considered.

While I understand that your work as Environmental Assesment Practitioners is not limited to shale gas, the following are the items I feel should be addressed in your EIA processes and documentation for exploration applications for oil and unconventional gas.  Please Note that exploration is one of the four scenarios considered in the SEA – namely Scenario 1.

All sites are rehabilitated, wells permanently plugged and monitoring of abandoned wells is implemented. 

• In all the documents we have seen, there has been no mention of these post exploration activities, but perhaps we have short memories, overloaded with all this bumpf.
• For those not abandoned, that is for the wells where sufficient gas is discovered, they therefore become permanent and thus exploration leads to production.
• We believe that this means that extraction cannot be excluded from your assessments! A precedent was set in the Netherlands where a judge made exactly this ruling.

Exploration is the first stage of the shale gas development (SGD) cycle. It is concentrated in the initial 2-3 years of the development cycle, but is undertaken throughout the life of the development to  inform the location of additional drilling and production operations.

In our minds, this also adds to the requirement that exploration assessments deal with the production phase impacts.

The appraisal stage follows exploration, and for a single campaign typically lasts about 2-3 years. It involves the drilling of appraisal wells, which are vertical wells with horizontal sections to ascertain potential yields of shale gas within the target formation, following test fracking. Drilling, fracking and other equipment and materials and waste receiving facilities are contained on the well pad. An area of similar extent to the well pads is developed for temporary accommodation of drilling crews in the region. If, during the exploration or appraisal phase, it is revealed that technically recoverable reserves cannot be economically exploited, decommissioning is implemented.

This means that the social assessment is critical during exploration phase EIA, as by the Appraisal stage it is too late – the damage to the social fabric will already be done!  Interesting is how long one loses control over one’s land – Exploration 2-3 years, Appraisal 2-3 years, Production 10-30 years, decommissioning 5-10 years.  What this means is that if the land is your legacy, your family will have to wait at least 20 years before it can be used again, that is, IF (BIG IF!) remediation is successful and has not sterilised/damaged the ecosystems so that the land is no longer productive (includes the availability of good quality water)!

• In the documentation SLR and EIMS has provided us so far, no mention of the test fracking is made, in fact they have specified that it will not take place.  At which phase will this be done, if the SEA shows it is part of the Exploration activities?
• This means that the social assessment and other missing specialist studies is critical for completion during exploration phase EIA, as by the Appraisal stage it is too late – the damage to the social fabric of communities and municipalities will already be done!
• How is the activity monitored for compliance for example in terms of buffers, if the wells can be angled in all directions?  How is it possible to check where it went?
• Fracking or flowback liquids – will the sand requirements mean more mining of our rivers and rural land? How will this issue be managed in view of the resulting erosion, destruction of riparian zones and loss of sand in terms of coastal sand budgets?
• The table below shows the exploration scenario impacts and activities.  Does this align with the information provided by SLR and EIMS?  If not, does this need to be reviewed?

During production, a typical shale gas wellfield could occupy an area of approximately 900km²  containing 50-60 wellpads, each of which drills around 10-15 wellbores during its life. Because the horizontal part of the wellbore extends several kilometers from the vertical part, the wellpads in a production wellfield can be expected to be around 3-5 km apart. While the production wellbore is yielding gas, a new wellbore is drilled from the same wellpad and angled in a different direction into the gas-containing layer, to take over production when gas flow from the first bore declines. The well pads are connected by a network of unpaved roads and buried gas pipe lines. Each wellpad occupies about 2 ha, and contains a large drill rig along with buildings, storage tanks, pumps, trucks, and generators.

How is the activity monitored for compliance for example in terms of buffers, if the wells can be angled in all directions?  How is it possible to check where it went?

Fracking or flowback liquids – imagine having this lot transported to, used and stored near your home or water supply?  Many of the additives are volatile – will become airborne.  There is no mention of the gas constituents in the fluids – these will contain the hazardous and volatile bits including BTEX – benzene, toluene, ethylbenzene and xylene!  Will the sand requirements mean more mining of our rivers?

Air Quality

Shale Gas Development without mitigation would be associated with a high risk of occupational exposure to air pollutants. There is insufficient information on air quality and GHG emissions in the Karoo to form a reliable baseline against which to measure the impacts of Shale Gas Development. There are no air quality monitoring stations within the study site, and only one near it, critically limiting information on air quality prior to shale gas development.

Wonder if this includes includes fugitive emissions – those gas releases that are not deliberate, but arise from leaks, spills and other incidents, including progressive well failure, which we have seen from the US increases with age of the well (with 6% of wells failing in the first year!).  What about emissions from flaring, from storing and handling of flow back fluids?

• Surely this means that baseline air quality monitoring must be done in all areas PRIOR to exploration?

Climate Change and Greenhouse Gas (GHG) Emissions

Shale gas presents both a risk of increased national greenhouse gas emissions and an opportunity to reduce emissions. The opportunity for emission reductions depends crucially on whether gas displaces coal (the main fuel in SA); or whether instead it displaces low-carbon energy sources; or whether gas is used in addition to coal. Shale gas used in place of coal for electricity  generation provides an opportunity to reduce GHG emissions, but the scale of reductions is slight in relation to the magnitude of national GHG emissions now and as projected over the period of SGD.

This is proof that it will not be an improvement worthy of pursuing for Climate Change Mitigation!

• This aspect has not been properly assessed by either SLR or EIMS in their documentation to show these significant impacts.  Note that the authors claim that methane is 20-30 times more dangerous as a greenhouse gas than carbon dioxide, while others claim it is closer to 100 times!

Tremors & Earthquakes

SGD by hydraulic fracturing increases the likelihood of small earth tremors near the well bores.  Only a few are likely to be strong enough to be felt by people on the surface. Many studies, in several parts of the world demonstrate an increase in small earth tremors during hydraulic fracturing. The possibility that hydraulic fracturing will trigger damaging earthquakes (i.e. of magnitude 5 or greater) through interaction with natural faults cannot be excluded, but the risk is assessed as low because the study area very rarely experiences tremors and quakes.

• This shows that a study needs to be done in each area to assess the impact, especially in the vicinity of buildings and dam walls!  The extent of the impact will be location specific and as we do not have any idea yet as to where the exploration will be done, how can this impact be assessed effectively?  This aspect needs to be monitored prior to exploration too!

The elements of the study area most vulnerable to earthquakes are heritage buildings made of unbaked clay bricks, and poorly-constructed low-cost housing.  A denser network of seismographs is needed in the region prior to the commencement of hydraulic fracturing. The seismograph would need to function throughout operations and after closure until seismicity decays near to background levels.

Have a look at the map to see where shudders are measured.   uMzimvubu Rhino and the Sungu/Motuoane areas look like problems…

Water – both surface and groundwater

Water availability in the study area is already severely constrained, and thus the capacity to supply water for SGD from existing local sources is very limited. Surface water availability is generally low. Most streams are non-perennial, episodic and ephemeral, with very high inter-annual variability. The surface water resources in the study area are already stressed (and in many areas over-allocated) to meet the demand of existing users. Central karoo landowners are mainly reliant on groundwater resources for domestic and stock water supplies. Groundwater recharge is typically low and sporadic. The development of groundwater resources to meet shortfalls in surface supplies is increasing, particularly during drought years, and in many areas already supplies 100% of the demand. The availability of potable groundwater resources in the study area to meet the additional demand of development plans not involving SGD – such as irrigated agriculture, tourism or mining –  is seriously constrained.

Water – this is the clincher!  For us, it is both surface and groundwater – remember that groundwater daylights into our springs and streams.  We cannot eat or drink gas, so surely it is relegated to the bottom of the water allocation log in a water constrained country such as ours?  I cannot think of a single part of the gas target areas being ‘flush’ in terms of water availability or quality.

• We are reeling from the effects of a drought which has been exacerbated by Climate Change driven by emissions from the use of fossil fuels.  Who will have to go with less or without water, so that exploration and then extraction requirements can be met?  This question has not been answered by either EAP so far.
• Groundwater has to be considered a future resource, even if it is not being used presently and the quality is not of drinking water standard
• Groundwater can daylight and flow into surface water resources.  This needs to be acknowledged and taken into consideration when dealing with water issues.

Surface spills on-site and along transport networks are the most likely source of water resource contamination resulting from SGD. SGD-related activities such as hydraulic fracturing, road building and workforce accommodation will place an additional demand on water resources and present a risk of contamination. Non-SGD activities such as uranium exploration and mining will compound this demand and pose additional contamination risks. The impacts on water quantity and quality are cumulative. 

Impacts following the completion of SGD (e.g. from failed well linings or capping structures on spent production wells) are a cumulative and inevitable legacy issue far into the future.

SGD must not proceed before a comprehensive set of baseline water resource data for the study area has been established. This must include surface water availability and verification of existing use (including the water resources needed to meet environmental requirements, the “Reserve”). The baseline must also include quantification of the quality of surface water and groundwater. Ongoing water resource quality monitoring including general and SGD-specific determinants is essential during and after SGD. 

There is currently a deficit of laboratories in South Africa to undertake the necessary analysis for water chemistry monitoring in relation to SGD. Although most accredited local (South  African) laboratories are equipped to carry out routine water analyses (e.g. major cations and anions), none are presently capable of analysing for determinants such as δ¹¹B, ³⁶Cl/Cl, ⁴H, ³H/^{4 26} H, and CH₄.  Sufficient lead-in time must be allowed for such facilities to be set up prior to SGD; baseline establishment in the immediate term may require the use of internationally-accredited laboratories.

This comment on Water is specially noticeable with the (mis)handling of the drought and lack of planning to mitigate the impacts.   What will happen when gas production takes more water?

• These requirements need to be stated in the Exploration documentation, so that they can be assessed and plans put in place to implement.

Current lack of infrastructure and institutional capacity for water management is a constraint in the karoo. Insufficient institutional and human resource capacity is a severe constraint to the implementation and execution of a robust and effective water resource monitoring and management programme for SGD. This constraint will apply to regulatory authorities, who often lack the necessary skills and the will to exert enforcement, and less so to the SGD industry, which it is expected will mobilize the necessary resources to meet regulatory requirements in this regard. This constraint is particularly relevant to independent monitoring and evaluation activities directed at ensuring compliance of the SGD industry with the regulatory requirements. The likelihood of environmental non-compliance is increased by poorly capacitated regulators.

• This is relevant to all areas under threat of exploration. The lack of planning and capacity is especially noticeable with the deepening drought.  For example, the KZN Mvoti WaterWorks is only able to treat 13% of capacity as there is no further water available from the river and the dam is perilously low.  They are now drilling for groundwater in the river.
• Industry in Richards Bay is already reeling from the downturn in the global economy and has had to cut production to meet the ever-reducing water allocations.
• We already have mining companies in N. KZN allegedly stealing water from farm dams and other resources.

Waste Management

SGD will generate substantial volumes and new types of waste in the study area.  These include  liquid wastes such as flowback fluids, solid mining wastes such as bore fragments and cuttings, industrial wastes such as used machinery and supplies, as well as more conventional wastes such as sewage, domestic water and construction waste. 

The existing legislated waste management provisions are adequate to reduce the waste-related risks of SGD to low, if rigorously enforced.  Currently, no hazardous waste sites are licensed for the disposal in the study area. This means that any hazardous waste would need to be transported and disposed of outside the study area. Mining-related waste, including that from SGD, is currently classified as hazardous, thus requiring specialized disposal sites and procedures. If this were to change with respect to SGD, wastes could legally be disposed in municipal landfills, which are currently completely inadequate for this purpose  and could have health impacts if people are exposed to it. Technologies employed at municipal  landfills are inappropriate to deal with the quality of the waste water generated by SGD and the design  capacities of these facilities are also insufficient to deal with additional volumes. Leach management and treatment is a pre-requisite for disposal of shale waste to landfill due to the presence of a range of toxic chemical additives and potential radioactivity and salinity in flowback water (leachable Naturally Occurring Radioactive Materials (NORMS). These substances require particular handling for safe disposal. The institutional capacity, skills and knowledge to implement and enforce waste regulations, norms and standards is limited, especially at local implementation level and will therefore have to be strengthened before SGD is approved.

It is a local authority function and where is it adequate?

• Self explanatory what is required prior to exploration.  How will the rural towns cope with these additional wastes?

Biodiversity & Ecological Impacts

The study area includes relatively high levels of biodiversity, including highly sensitive and unique ecosystems and species. Seven different biomes and 58 vegetation types, 119 endemic or near endemic plant species, and threatened animal species have been recorded from the study area.  Areas identified in this assessment as being of very high ecological importance and sensitivity are irreplaceable if substantively damaged. Widespread impacts in these areas would undermine the ecological integrity of the study area (and more broadly, the Karoo). Any activities, including but not restricted to SGD, in these areas are assessed as very high risk. The very high and high ecological  importance and sensitivity areas make up an estimated 55 % of the study area. Only 5 % of the study area is formally protected in National or Provincial reserves. The primary mitigation for SGD with respect to biodiversity is securing the areas of very high and high ecological importance and sensitivity. This effectively frees up medium-low and low areas for development. The Karoo is an arid ecosystem characterised by ecological processes that operate over extensive areas.  Mitigation of ecological and biodiversity impacts must take place primarily at the landscape scale rather than solely on the physically-disturbed footprint. Impacts on species, ecosystems and ecological processes extend well beyond the physical footprint of the activity. For many species the impacts of noise, pollution, erosion and disturbance can extend for hundreds of metres or kilometres from the source. A major concern is that the roads, pipelines and powerlines associated with SGD will result in fragmentation of the landscape. Loss of connectivity, edge effects and disruption of ecological processes associated with a dense network of linear structures could undermine the biodiversity integrity of the study area. Impacts on species and ecological processes are likely to have cascading effects on other species and processes.  The cumulative and unforeseen impacts of SGD on biodiversity, as well as effectiveness of mitigation, must be monitored. The outcomes of the monitoring programme need to dynamically inform ongoing strategic and regional level decisions on SGD.

A study needs to provide this information for each area where exploration may take place.  Biodiversity loss affects ecosystem functioning and our water resources.

• It is not acceptable to just count species and provide their status as is the usual way of assessing these impacts.
• EAPs have to do better than provide the usual fare dished up in the reports we usually review, to ensure that biodiversity is properly studied so that the impacts can be effectively predicted and assessed.

Impacts on Agriculture       

The biggest potential threat of SGD to agricultural production in the study area relates to the use and availability of water resources. SGD poses potential risks to both the quantity and agricultural usability of surface and groundwater resources. Opportunities may exist to use water produced through the SGD process for agricultural production purposes, should it be either of an acceptable quality or amenable to purification. SGD will not have a significant impact on agricultural productivity in the long term if the threat to ground water resources is adequately addressed. Any intervention that destroys current land-based livelihoods is likely to have a long-term impact on the resilience of both the area and its land users. Local land users draw on profound local knowledge to sustainably use these vulnerable land-based resources. Fragmentation of the  landscape to accommodate SGD must be carefully planned to minimize the negative impacts on the viability of agricultural enterprises.

Interesting to see how they quantify the amount of land that is deemed agriculturally sensitive as a % of the target area.  In terms of food security, this is essential to have.

• We need a sensitivity index map for the areas where exploration is proposed.
• The EAPs also need to quantify the amount of land that is deemed agriculturally sensitive as a % of the target area.  In terms of water and food security, this is essential to have.
• Existing livelihoods must be respected in terms of the resilience they provide to individuals, families and communities.

Access – Privacy, Safety and Security

Shale gas exploration and exploitation will put the protection of the privacy and security of land  users at risk. Currently land users enjoy high levels of control over the farm-based resources  resulting in minimal losses of livestock and other property, and good levels of overall safety and security of rural communities, including land users, farm workers and their families. This is in part a result of minimal through-traffic on most farms, and relatively stable local populations. The anticipated influx of staff of shale gas companies and the situating of SGD operations on farm land will expose farm property, for example livestock, to theft and increase vulnerability of local communities to farm attacks and violence. Long-term monitoring and evaluation is essential to measure the effectiveness and efficiency of mitigation measures applicable to agriculture under all scenarios of SGD.  The outcomes of these monitoring and evaluation processes must be fed back to relevant stakeholders to ensure continuous improvement.

• In view of the increasing crime rates in rural areas, the safety and security aspects must be effectively addressed prior to exploration.
• This cannot be left to local police stations and municipalities to bear the load in terms of already stretched and scarce resources.

Tourism

Tourism is a growing economic sector with the capacity to drive growth and upliftment in rural areas. Tourism has become the largest economic sector in the study area in terms of number of enterprises.  All study area towns are reliant on tourism, some more so than others. The rural landscape is an important resource for specialised tourism niches, such as ecotourism, agritourism, hunting and adventure tourism. This has  dispersed tourism activities into the rural areas of the study area. Tourism is the fastest growing sector in most Karoo towns, thus its importance in the study area is expected to further increase in future.

The groups are: business tourists and those visiting friends and relatives (VFR); people travelling through the region; and niche tourists who actively seek  out the Karoo as a destination in order to experience ecotourism, adventure tourism, agritourism, culinary tourism, hunting, stargazing, etc. Business and VFR tourism is expected to increase under SGD but might experience crowding out if shale gas workers use tourist facilities for accommodation  in the towns of the N1, N6 and N9 routes. Tourists passing through the study area would experience traffic densification and possibly also crowding out in these towns. Niche tourists are most sensitive to disruption of peace and quiet and are also the most dependent on rural areas. They would be consequently be the most sensitive to SGD.

The most likely negative impacts of SGD on tourism are expected to be traffic densification and its associated noise pollution. This results from slow moving trucks continuously ferrying materials  needed for SGD, also through towns in the assessment area. Other impacts would include visual impacts, a loss of sense of place, potential pollution (especially water) and small earth tremors. All of  these changes could impact on the value of the Karoo brand which is associated with an undeveloped rural landscape. Negative impacts on the tourism sector would increase the risk of losses of employment and value addition to local economies.

• This is one of the issues that is glossed over in the exploration documentation we have seen and should take into account how the SEA deals with it.
• Tourism is a significant driver of the local and regional economies and this is in all the IDP’s and SDF’s of local and district municipalities.
• Tourism is incompatible with mining and thus it is a significant issue to be raised and addressed.

Impacts on the Economy

Shale gas development could deliver highly significant economic opportunities, but the extractive nature of SGD also brings economic risks. In both respects it is a little different to other types of mining. The opportunities include an increase in the national and local economic activity and employment. The principal risks relate to the ‘boom and bust’ nature of extractive industries, and to  the effects of large new inward investments on increasing the value of the South African Rand, which would make exports less competitive.  Shale gas development would increase employment opportunities. The ‘Big Gas’ scenario would be associated with approximately 2 575 direct operational jobs in drilling, trucking and power generation with residents of the study area probably able to fill 15% to 35% of these positions, increasing over time as training proceeds. It should not be assumed that indirect and induced impacts in terms of jobs in the study area would reach the same level as direct impacts.

The risk that SGD could ‘crowd out’ other economic sectors in the study area, such as agriculture and tourism, by causing rises in the prices of labour and other inputs, is generally  low for the scenarios considered. An important proviso is that shale gas development should not  seriously compete with local water users or pollute local water supplies.  Local government finances are likely to be put under significant strain particularly for the large scale development scenario. Appropriate mechanisms will be needed to effectively alleviate this strain.

There is a risk that the residual costs associated with SGD become the responsibility of society. Financial mechanisms will be needed to ensure that developers make adequate financial provisions to allow the state to deal with remediating remaining impacts in the event of pre-mature closure and longer term risks associated with the post-closure period.   Adequate and unambiguous compensation mechanisms will be needed for land owners to cover the use of their land, and for other affected parties where environmental and other damages cannot be mitigated. Property values on farms near where drilling occurs are likely to decrease. This applies to places exposed to water supply or quality deterioration, and to places whose amenity value  is reduced by visual, noise, traffic or security risks. This loss can be balanced by adequate compensation. Property values in towns, on the other hand, are likely to increase due to increased economic activity assuming key externalities such as those associated with increased truck traffic can  be managed.

So much to be managed and mitigated. By whom and with what funds?

• This issue is merely presented as a positive impact – all the jobs (over-estimated somewhat?), knock on effects for entrepreneurs and municipal coffers – you name it.  However, if mining were such a money-spinner to so many, why did the Marikana Massacre occur and why are all the mining towns having so many service delivery protests?
• So much to be managed and mitigated….  By whom and with what funds?

The Social Fabric

Large investments in small-town areas create boomtown conditions in the local economy. SGD under the Small Gas scenario, and especially Big Gas scenario, will create a significant mining sector in the study area. This will be associated with increases in construction, trade (wholesale and retail) and business services, which are likely to have extensive multiplier effects in the local economy, as well as job creation in these sectors. However, any threat to water quality and quantity would have significant and rapid negative consequences for local boomtown economies.

Actual or anticipated large investments in small towns will stimulate rapid in-migration of workers and work-seekers, some of them with families, which will challenge the often already-stressed capacity to deliver services. SGD will place pressure on housing, guest houses, hotels, caravan parks, and retail services. Housing demand is likely to overflow into informal settlements. Municipal planning and infrastructure provision typically has a fairly long lead time. Demands on water reticulation, electricity, sewerage, schools, clinics and local roads are likely to exceed capacity at least in the medium-term, even under intensive exploration (Scenario 1) and Small Gas.

Rapid development is associated with disruption of the social fabric and feelings of insecurity. The in-migration of people typically experienced in boomtowns leads to an increase in undesirable social outcomes such as teenage pregnancies, alcohol and drug abuse, property crime and violent crime. This puts pressure on the police, social welfare and health services. The challenge to local people’s sense of identity and the feeling of accelerating and out-of-control change from the status quo increases the sense of insecurity and threat to the social and moral fibre of the community among local people, which could result in conflict with in-migrants and xenophobia.  SGD, while anticipated to raise the mean social welfare at national and local level, may perversely simultaneously accentuate social inequalities and schisms.  Governance processes and institutions need to be strengthened to minimize such unintended outcomes

• Ditto above comments!

Impact on Health

The health status of the present local population in the study area is below national average, making them more vulnerable to adverse human health effects from SGD. This is despite the perception of the Karoo as a healthy environment, and is largely related to poverty, inadequate housing, unsafe water and sanitation, and insufficient health infrastructure. Investment in health  infrastructure and improving socio-economic status, arising from SGD or other sources, would  improve the health outcomes in the communities.   People living close to shale gas infrastructure (well-pads and roads) can anticipate negative health impacts through air, water and noise pollution. Through mitigation and exclusion zones the anticipated human health impacts on communities can be reduced.

SGD workers are potentially directly exposed to toxic substances for extended periods. Short-term dermal and respiratory symptoms are common among SGD workers. Some cases of death have been reported in countries with a history of SGD. Airborne silica exposure at the well-pad is an important cause of respiratory issues. Mitigation options, such as engineering solutions and personal protective equipment, can substantially reduce the workers’ exposure.

Baseline monitoring is crucial to attribute a future negative or positive impact of SGD on human health in the study area. Currently the available information on health issues in the study  area is inadequate to form a baseline. Metrics such as incidence of asthma and other respiratory problems, dermal irritations (rashes), cardiac, cancer, birth weights, birth defects, APGAR scales, kidney and liver, infertility, neurological impairment need to be monitored.   Uncertainties in the chemicals to be used and evidence of the health impacts that might be expected are the major restriction in the health impact section of this study. The assessment is  based on international data and experience. Many of the chemicals used in SGD do not have sufficient health data associated with them to make an assessment. Since the activity of hydraulic fracturing is relatively new in relation to the time needed to assess long-term health effects as well as trans-generational effects, scientific evidence that can be used with certainty is scant, but some of the chemical used are known to have long-term and transgenerational health effects.   Detection of health impacts resulting from SGD will require baseline and ongoing monitoring for air and water quality, and health, especially for health symptoms associated with SGD. This will need to be carried out prior to initiating the activity to enable ascribing any future health effects  to a specific cause. Health issues should be recommended for inclusion in the Regulations for Petroleum Exploration and Production, which currently do not consider them directly.

There is no discussion of the health effects from Climate Change – imagine all these additional exposures for rural communities with poor health status already?  They are not at all resilient when you add in the impacts from Climate Change – extremes of temperature, floods, drought, new vector-borne diseases, etc?

• The poor will get poorer in every which way!
• Who will do the baseline health assessment, where and by when?

Sense of Place Values

There is insufficient underlying research and documented evidence for this assessment to adequately evaluate the issue of sense of place.  There is not one, but are several, “senses of place” in the Karoo. Some of have local significance, while others are sensed by people living outside the area (for instance, by tourists), and perhaps never visiting the area (for instance, the senses of place resulting from elements of scientific significance or artistic representation). The multiplicity of senses of place has been identified from publicly available literature or media and potential areas of conflict or sensitivity highlighted.

Shale gas development in the Karoo will affect values associated with sense of place, in some cases positively and in others negatively, and in some cases irreversibly.  Sense of Place values are seldom adequately addressed in public participation processes in EIAs and development processes, although they often turn out to be major issues. For them to be adequately addressed would require detailed empirical research to elucidate the specific sense of place values in particular contexts. One way to fill this critical gap would be to include such investigations in studies such as EIAs, Spatial Development Frameworks (SDFs) and Environmental Management Frameworks (EMFs). It is recommended that both quantitative (Likert type surveys) and qualitative  (ethnographic type interviews) be applied to gauge sense of place. The results of this research should  become public and made part of the processes which inform decision-making on specific SGD applications.

• This highlights the need for a moratorium until the regulators have a better handle on what is needed prior to applications being submitted for authorisation.

Visual, Aesthetic and Scenic Resources

SGD and its associated secondary developments, without mitigation, is likely to lead to the visual fragmentation of Karoo landscapes, and transformation of its pastoral or wilderness character to an industrial connotation in the affected areas. The visual impacts of SGD must be considered in conjunction with visual impacts resulting from other developments, for instance the possible uranium mining and the roll out of wind and solar energy in the study area. Mitigation consists primarily of restricting SGD activities in visually sensitive locations.  A number of scenic ‘hotspots’ in the karoo could be affected by SGD. These need to be taken into account in EIAs and other permitting processes. Currently, visual resources have no specific legal protection in South Africa, except under the definition of the National Estate in the National Heritage Resources Act. It is advisable that national, provincial and local authorities enact legislation or by-laws to prepare for the effects of possible shale gas activities on visual resources. There is no standard approach to mapping or rating the value of scenic resources in South Africa.

The scenic resources identified in this assessment correlate closely with areas of biodiversity and heritage significance as described in other sections. The escarpment is a particularly sensitive feature of the study area, although impacts of varying significance could occur anywhere.

• The assessments so far have not shown which areas are sensitive from this point of view!

Impact on Heritage Resources

The risk to heritage resources from SGD varies markedly from place to place within the study area. It depends on the type of heritage resource, the specific locations of well pads, access roads and related infrastructure, and the amount of induced seismic activity that occurs. There is no part of the study area where there is no risk to heritage resources.  The impacts on heritage from the small and large SGD scenarios could be high, but are typically confined to particular areas. There is a potential for extensive but low intensity impacts from SGD exploration. Care in the exact positioning of the infrastructure and the implementation of management and mitigation measures during all phases, as required by legislation, will help to reduce the significance of the impacts that would be experienced. The cultural landscape is the most difficult aspect to deal with in terms of mitigation. Minimising the amount of landscape scarring that takes place and effective closure phase rehabilitation are key aspects of heritage impact mitigation.

Current institutional capacity in terms of application of the National Heritage Resources Act (NHRA) is limited and a marked improvement will be required before SGD commences. The National Heritage Resources Act outlines procedural due diligence for heritage management and development. The status quo shows that many provincial and local authorities have yet to comply with the provisions of the NHRA. The functionality of the single national and three provincial heritage authorities overseeing the study area is highly variable and this will affect the quality of decision-making and commenting. The South African Heritage Resources Agency, as the national authority, should take responsibility for all applications related to shale gas development and source comment from relevant provincial and local authorities.

• We trust the Heritage Impact Assessment is done thoroughly and addresses all these issues effectively.

Noise

Acoustic noise has a marked impact on the physical health of people and on their psychological wellbeing. The Karoo area is a quiet area. Residual day- and night-time noise levels are  approximately 33 dBA and 25 dBA respectively (LAeq). This is 10 dB below the typical levels published in standards for rural areas. This is a significant difference. Subjectively a change of 10 dB  is perceived as a doubling of “loudness”.  Exploration phase noise impact is likely to be localised and of short duration. Noise would be generated predominantly by trucks, and would only be noticeable in the immediate vicinity of exploration activities, for the duration of the activities.   The construction, operation and decommissioning phases of SGD will likely cause noise impacts for humans and animals on sites within about 5 km of the sites. Noisy activities during the operational phases are expected to run constantly (day and night) for 6–8 weeks at a time, repeated 15 every 6 months at every wellpad, for a period of a decade or two, with quieter activities between.  Night time noise impacts are therefore most likely, when residual noise levels are at a minimum.   There is additionally a risk of noise impacts emanating from the surrounding roads due to increased heavy goods vehicle road traffic, especially under a Big Gas scenario, and if the roads used are otherwise quiet and seldom used. Proposed sites of noise generating activities will need individual Noise Impact Assessments in 24 accordance with SANS 10328 to determine the likelihood and severity of these impacts. Noise control, attenuation and monitoring will likely be required for all sites. The extent of the required measures will be determined by the Noise Impact Assessment.

• This is a significant impact with really easily implementable requirements shown above.
• Remember that noise goes outwards and upwards from the source, so is locality specific!  Hence the need to know where the target sites are and the assessments done there, not generally!

Integrated Spatial and Infrastructure Planning

Towns in close proximity to SGD activities will experience growth exceeding projections based on past trends. Enhanced resource and institutional capacity to plan for, and address increased service delivery demand for housing, water provision, social services, electricity and roads will berequired due to increase in demand by households and local enterprises (both because of new direct jobs and spin-off opportunities), as well as high probability of increased in-migration and expected  increase in indigent population.   The most significant direct impact on infrastructure is expected to result from the construction  of a network of geographically scattered private local access roads and well pads. Even though  most of this will probably be on private land, it will have implications for the need for scarce construction materials. This will have a major impact on availability and cost of scarce raw materials such as gravel and water. Action will be required to source construction material and identify and approve local sites for extraction of raw materials. This will be accompanied with the increase in number and complexity of land development applications and required expanded technical capacity development.

• If water and building sand availability (and sand mining) is already causing environmental harm and conflict how will this be managed?
• Who will bear the cost – society or the applicants?

The increase in traffic by heavy vehicles on regional roads will be substantial. This will require mitigation in terms of initial road rehabilitation to an adequate baseline and an increased cycle and quality of maintenance, avoidance of certain routes as well as development of expanded and enhanced law enforcement and safety and emergency response capacity. There may also be a need to develop pipelines and re-establish the rail infrastructure in the sub-region to reduce the pressure on the road infrastructure. There is thus a critical need to audit and establish the current baseline condition and usage of national, regional and local roads to inform mitigation responsibilities in future. Regulatory uncertainties and limited municipal capacity to facilitate an ongoing processes of land use and land development applications associated with shale gas exploration and development could pose risks to already limited municipal governance capacity and result in regulatory bottlenecks. This could impede effective decision-making and sustainable land development.

Challenges with the rolling out of the Spatial Planning and Land Use Management Act, 15 2013 (SPLUMA), includes: major capacity implications for municipalities; procedural uncertainty with regards to land use and land development applications; and differences in its application between the provinces, with the Western Cape Land Use Planning Act, 2014 (LUPA) applicable in Western Cape Province. Clarification of legal and implementation practices in the land use and land development regulatory framework, as well as provincial support to municipalities in development of appropriate municipal planning by laws, the update of spatial planning and land use management instruments, and the establishment of institutional capacity for municipal planning tribunals and compliance monitoring will be highly supportive. Integrated spatial planning will be essential to deal with the multi-scaled and intersectoral issues that result from activities of magnitude and duration of shale gas development and downstream development. Spatial Development Frameworks (SDFs) and Integrated Development Plans (IDPs) plans in the area will require an update. Firstly, to ensure that they consider implications of possible developments and projected growth and facilitate participative visioning, planning, prioritisation, budgeting and mitigation across possible shale gas exploration and production periods and municipal  planning cycles. Secondly, to fulfil new regulatory functions, provide guidance to a range of sector plans (i.e. integrated housing and transportation plans) and enable the infrastructure pipeline necessary to design, procure, construct and maintain infrastructure. Given a host of other activities in the area, the preparation of a Regional Spatial Development Framework (RSDF) (in terms of the Intergovernmental Relations Framework Act, 2005 (IGRFA), and the Spatial Planning and Land Use Management Act, 2013 (SPLUMA)) could contribute to pro-active intergovernmental planning  between the respective local and district municipalities, provinces, relevant provincial and national sector departments and other role players (including local communities interest groups business, and state owned enterprises such as ESKOM and SANRAL). The governance capacity for coordinated and integrated spatial and infrastructure planning, investment and management to deal with the implementation of potential shale gas exploration  and development is currently limited.

Given the anticipated extended timeframes, geographic uncertainty and phased approach to shale gas exploration and production activities, the establishment of regional (cross provincial) spatial and integrated development planning capacity (supported by specific task teams) could enable a cost effective shared capacity to provide the necessary technical capacity to inter alia assess applications, assist with pro-active planning, monitoring and control of impacts on land uses and activities.

• How will these recommendations be implemented with these current applications?

Clearly the SEA has raised many issues and made recommendations.  The EIA’s will need to review this work and integrate ALL the recommendations into the process.  We look forward to a response from the EAPs for Rhino, Sungu Sungu and Motuoane, to whom we addressed these concerns.  We will share their replies. Please subscribe on the Home Page to ensure you don’t miss them.