Case Decision - 198081

The Maritime and Underwater Cultural Heritage (MUCH) unit at the South African Heritage Resources Agency (SAHRA) would like to thank you for submitting the Draft Scoping Report (DSR) under section 38(8) of the National Heritage Resources Act, No. 25 of 1999 (NHRA) as part of the application for Environmental Authorisation (EA) to undertake exploration well drilling in Block 5/6/7 off the South-West Coast of South Africa. This follows from an exploration right no. 12/3/224 awarded under the Department of Mineral Resources and Energy (DMRE).
The proposed activities include drilling of up to 5 wells in a 10 000 km2 area, at depths between 700 m and 3 200 m, between 60 km and 170 km offshore from the South-Western tip of South Africa. Each well will be drilled in phases, starting with a mobilisation phase, followed by a drilling phase, the well abandonment phase, and finally the demobilisation phase. The drilling involves the use of Water-based Muds (WBM) during the riserless drilling and Non-Aqueous Drilling Fluid (NADF) during the risered drilling. Flaring might occur if hydrocarbons are discovered. This drilling will be done from a semi-submersible drilling unit or drillship with between two and three vessels supporting the drilling ship as well as a helicopter. The commencement of these activities is set for the earliest at quarter four of 2023.
The role that SAHRA plays is briefly summarised under section 2.1.4 of the DSR. The last sentence could be misleading as the NHRA states under section 2(ii)(c) that it is “wrecks… older than 60 years or which SAHRA considers worthy of conservation…” that are considered archaeological as opposed to all wrecks, as alluded to in the DSR. This must be amended to reflect the types of wrecks and wreck resources that fall under SAHRA’s jurisdiction. This must also be amended under section 2.2.8 of the DSR where this same misleading statement is paraphrased. Section 7.9.1 of the DSR outlines that previous communications with SAHRA claimed there to be no known wrecks in Block 5/6/7. Although this statement remains true, as the suspected locations of several wrecks have not been verified, more research has since been conducted, and there are now at least two suspected wrecks, the Argo (1942) and the Belgian Fighter (1942) within the proposed exploration drilling area alone. These two vessels were torpedoed during WWII with the loss of at least 23 lives. SAHRA thus insists that a Maritime Heritage Impact Assessment (HIA) be conducted by a qualified maritime archaeologist.
However, SAHRA is pleased to see the mitigation measures proposed in the DSR in that if a wreck resource is discovered, that the well-drilling location would be shifted to avoid this resource. This mitigation measure must be expanded upon to include any discovered heritage resourses and to ensure that sufficient distance is provided between the heritage resource and the possible impact area of the well-drilling. SAHRA reiterates though, that according to section 35(3) of the NHRA, if any heritage resource is discovered this must be reported to SAHRA immediately. Heritage resources that might be applicable in this case, include, but are not limited to; archaeological fossils, palaeontological fossils, and pieces of shipwreck material older than 60 years.
SAHRA is also pleased to see the inclusion of a Cultural Heritage Assessment (CHA) under section 3.3.1.3 of the DSR as part of the Socio Economic Assessments to assess the impacts on indigenous beliefs and intangible heritage. The details thereof as outlined under section 7.9.2 and 9.2.2.5 of the DSR appear satisfactory and SAHRA looks forward to seeing the outcome thereof.
Please not that all updates and/or changes to the project, supporting documentation, correspondence, reports, or any other work relating to the project must be uploaded to the case on SAHRIS to provide SAHRA with the opportunity to comment. SAHRA does not accept emailed documents or hard-copy documents received via post.