GROUNDWORK’S RESPONDING STATEMENT TO KARPOWERSHIP SA (PTY) LTD’S APPEAL AGAINST THE ENVIRONMENTAL AUTHORISATION REFUSAL DECISION (EA NO. 14/12/16/3/3/2/2005): NGQURA
Summary
This responding statement, submitted by groundWork, argues against an appeal by Karpowership SA (PTY) Ltd regarding the Department of Forestry, Fisheries and the Environment's (DFFE) June 23, 2021, decision to refuse Environmental Authorisation (EA) for a gas-to-power project at the Port of Ngqura. groundWork contends that the project is neither necessary nor desirable, citing significant environmental risks, inadequate public participation, and the existence of more sustainable energy alternatives.
Key insights
- The proposed Karpowership Ngqura Project involves a 20-year operation featuring two Powership floating mobile vessels and a Floating Storage Regasification Unit (FSRU) with a 540MW capacity, alongside a 7.5km transmission line and a subsea gas pipeline.
- The project is estimated to have a 'very high' climate change impact, with total emissions expected to exhaust approximately 0.82% of South Africa's national carbon budget. Over 20 years, the project alone would emit roughly 17 million tCO2e, with additional Scope 1 and Scope 3 emissions.
- groundWork disputes the 'need and desirability' of the project, citing studies from CSIR and Meridian Economics which suggest that South Africa does not need to expand gas infrastructure for the foreseeable future and could instead prioritize wind and solar generation.
- The DFFE refused the Environmental Authorisation based on several critical gaps, including the inability to determine actual and potential impacts on the environment and socio-economic conditions due to missing underwater noise assessments and discrepancies in reports.
- The public participation process was deemed deficient and not in line with NEMA or EIA Regulations. Specifically, the draft environmental impact assessment (DEIR) was not subject to the required 30-day public participation period, and documents were intermittently removed from the website.
- Significant new information was added to the Final Environmental Impact Report (FEIR) without the required 30-day public consultation, including revised GHG emissions data and peer reviews of climate change and marine reports.
- The project location poses risks to highly sensitive biodiversity, including the Addo Elephant National Marine Protected Area, the Algoa to Amathole Ecologically or Biologically Significant Marine Area (EBSA), and the African Penguin population on Jaheel Island.
- Expert analysis by Michelle Fournet indicates that Karpowership failed to conduct necessary site-specific underwater noise propagation modelling, relying instead on inapplicable data from Ghana.
- The socio-economic impact assessment is criticized for being defective, as it focuses on broad national electricity benefits while scaling down negative impacts to a local level and failing to account for losses in tourism and fisheries.
Cite the original document
- APA
- Centre for Environmental Rights (n.d.). GROUNDWORK’S RESPONDING STATEMENT TO KARPOWERSHIP SA (PTY) LTD’S APPEAL AGAINST THE ENVIRONMENTAL AUTHORISATION REFUSAL DECISION (EA NO. 14/12/16/3/3/2/2005): NGQURA. https://cer.org.za/wp-content/uploads/2021/08/groundWork-Responding-statement-on-Karpowership-Ngqura-EA-Appeal-19.08....pdf?x21779
- Chicago
- Centre for Environmental Rights. GROUNDWORK’S RESPONDING STATEMENT TO KARPOWERSHIP SA (PTY) LTD’S APPEAL AGAINST THE ENVIRONMENTAL AUTHORISATION REFUSAL DECISION (EA NO. 14/12/16/3/3/2/2005): NGQURA. n.d. https://cer.org.za/wp-content/uploads/2021/08/groundWork-Responding-statement-on-Karpowership-Ngqura-EA-Appeal-19.08....pdf?x21779.
- Wikipedia
- {{cite press release |author=Centre for Environmental Rights |title=GROUNDWORK’S RESPONDING STATEMENT TO KARPOWERSHIP SA (PTY) LTD’S APPEAL AGAINST THE ENVIRONMENTAL AUTHORISATION REFUSAL DECISION (EA NO. 14/12/16/3/3/2/2005): NGQURA |url=https://cer.org.za/wp-content/uploads/2021/08/groundWork-Responding-statement-on-Karpowership-Ngqura-EA-Appeal-19.08....pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}
- BibTeX
- @misc{centreforenvironmentalrightsndgroundworks, author = {{Centre for Environmental Rights}}, title = {{GROUNDWORK’S RESPONDING STATEMENT TO KARPOWERSHIP SA (PTY) LTD’S APPEAL AGAINST THE ENVIRONMENTAL AUTHORISATION REFUSAL DECISION (EA NO. 14/12/16/3/3/2/2005): NGQURA}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2021/08/groundWork-Responding-statement-on-Karpowership-Ngqura-EA-Appeal-19.08....pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }
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