/ 4 June 2021

Complaint brought against Karpowership enviro consultants for not doing study on underwater noise

A recent high court ruling on another matter led parliament’s portfolio committee on mineral resources and energy to halt the inquiry into the risk mitigation independent power producers procurement programme linked to Karpowership.

The environmental consultants for the controversial Karpowership project failed to conduct a specialist study of the potential consequences or impacts of underwater noise generated by gas-fired floating powerships on the environment and marine resources in Saldanha Bay, before submitting the final environmental impact assessment report (EIA) to the department of forestry, fisheries and the environment in April.

This is the basis of a formal complaint lodged on 31 May by the nonprofit organisation Green Connection to the department, which centres on Triplo4 Sustainable Solutions’ failure to comply with EIA regulations for the final EIA for the proposed gas-to-power powership project. The project has implications for the environment and small-scale fishers, who depend on a healthy ocean for their livelihoods. 

Liziwe McDaid, the strategic lead for the Green Connection, said there is not enough information about underwater noise and vibration levels from the floating power plant ships in the context of the port of Saldanha Bay.

“The sad fact is that the proper studies on the impact of noise were not conducted, and for consultants to suggest that further studies (after the fact) will address this concern and that the risk is ‘likely to be low’, is completely unacceptable,” she said.

This was not the aim of EIAs, “because then you are not providing the decision-maker with the full picture on which they can make a decision. If they do the studies after the fact and [the department] finds, ‘Oh, this is really bad, we shouldn’t have given the go-ahead,’ it’s already too late because they already have authorisation.”

The final EIAs produced by Triplo4 recommended the Karpowership project be given the green light in the port of Saldanha Bay, as well as in the ports of Richards Bay and Ngura. 

Albi Modise, the spokesperson for the department, said it had received the complaint and is following a process in line with regulation 14 of the EIA regulations of 2014, as amended

“The regulations require that as soon as a formal complaint has been received by the department, such a complaint and the intention to investigate must be communicated to the environmental assessment practitioner and the applicant and they must be afforded an opportunity to respond to the allegations being made.”

The department is expected to evaluate the allegations against the response. “Should it [be] found that there is merit to the allegations, a formal investigation is then initiated. The timeframes for the processing of the application are immediately suspended when the investigation is underway and formal communication is made with the practitioner, the applicant, complainant as well as interested and affected parties. 

“If the investigation finds that the conduct of the practitioner is indeed inconsistent with the requirement of the law, the practitioner is then disqualified and there could [be] criminal actions attached to their conduct,” he said.

A new practitioner would have to be appointed by the applicant to commence with a new EIA application process from the beginning, Modise explained.

The regulations governing the mandatory contents of EIAs, under the National Environmental Management Act have specific requirements, “which we believe have not been met in this case”, McDaid said.

There have been major declines in key fish populations in Saldanha Bay in recent years, particularly stompneus, elf and harders, she wrote in the complaint. 

At a meeting arranged by Triplo4 with small-scale fishers on 19 April, the issue of marine noise impacts on remaining resources was repeatedly highlighted as a concern, especially with the decline of fish stocks, such as the stompneus.

A marine ecology specialist study conducted as part of the EIA process in April described how the proposed floating powership facility in the port of Saldanha Bay is surrounded by important habitats such as Langebaan Lagoon, Malgas, Jutten and Marcus Islands, the subtidal benthic zone, the water body itself and aquaculture development zones. 

“These areas could be impacted by the surface noise and the underwater noise from the vessel operations,” the study stated.

Key activities associated with the proposed project that could be harmful to the marine environment include “increased noise levels from power generation machinery in the port intertidal and subtidal environments. “These may affect life functions, including individual health and fitness, foraging efficiency, avoidance of predation, swimming energetics and reproductive behaviour,” according to the study. 

“The sensitive receptors to noise within the port of Saldanha Bay are fish, diving and swimming seabirds … and marine mammals.” 

Chronic effects may occur with longer exposures to underwater noise, including developmental deficiencies and physiological stress. 

With its nutrient-rich waters, Saldanha Bay is an essential nursery habitat for many fish species, said the study, noting how juveniles are considered more susceptible to noise disturbances as they are less mobile, while adult fish and marine mammals can move out of affected areas.

The research, however, McDaid said, did not study these effects, and recommended that a baseline study of the underwater noise climate in the Port of Saldanha Bay is done so that a noise modelling study can be undertaken. 

While this study referred to a short-term study on underwater noise produced by powership operations in Ghana, it qualified these findings by stating that noise generation from the powerships needs to be studied in the context of the Saldanha Bay topography. 

“Sound waves will be absorbed and/or reflected by port structures. If we assume that the powership proposed for the port of Saldanha Bay is equivalent in sound generation to that moored in Ghana, then effects on the surrounding marine ecology would be unlikely. However … a better understanding of the underwater noise climate in the port of Saldanha Bay is required to place the noise generated by the powership in context,” the study says.

Another specialist study on noise impacts deemed it of “critical importance” that the current underwater soundscape of Saldanha Bay be determined, recommending a separate underwater noise impact assessment along with detailed underwater noise measurements using hydrophones in the important habitats and shipping routes into Saldanha Bay.

McDaid said that given the conclusions and recommendations of both of these specialist reports, the final EIA report is unable to present to the competent authority an assessment of a potentially significant impact, prior to authorisation of the project.

This was “namely the impact of sustained and continuous noise for 20 years on fragile and severely depleted fish populations (particularly juvenile fish) in Saldanha Bay, on which small-scale fishers depend for a livelihood”.

Triplo4 did not respond by the time of publication.