GROUNDWORK’S RESPONDING STATEMENT TO KARPOWERSHIP SA (PTY) LTD’S APPEAL AGAINST THE ENVIRONMENTAL AUTHORISATION REFUSAL DECISION (EA NO. 14/12/16/3/3/2/2007): RICHARDS BAY

This responding statement, submitted by groundWork to the Department of Forestry, Fisheries and the Environment (DFFE), argues for the dismissal of Karpowership SA (PTY) Ltd’s appeal against the refusal of an Environmental Authorisation (EA) for a gas-to-power project in Richards Bay. groundWork contends that the project is neither necessary nor desirable, citing significant environmental risks, inadequate public participation, and the existence of more cost-effective, renewable energy alternatives.

• The proposed Karpowership project in Richards Bay would consist of two powerships and a Floating Storage Regasification Unit (FSRU) with a 540MW capacity, a 3km transmission line with 13 towers, and a subsea gas pipeline. The project is expected to release approximately 17 million tCO2e over 20 years, with additional direct and indirect emissions, totaling roughly 0.82% of South Africa's national carbon budget.
• The project site is located in an ecologically sensitive area featuring irreplaceable Critical Biodiversity Areas (CBA), endangered mangroves, and rare estuarine systems. Specifically, the Richards Bay and uMhlathuze estuaries support 47% (652.1 ha) of South Africa's mangrove habitat, and the area is a preferred habitat for the Ocean Humpback Dolphin.
• 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. These reports indicate that a least-cost scenario involves rapidly building out wind and solar generation, and that new gas capacity is not required to prevent load-shedding for at least the next decade.
• The DFFE refused the Environmental Authorisation based on several material gaps, including the failure to conduct a qualitative Underwater Noise Impact Assessment for megafauna (such as the Humpback Dolphin) and the failure to consider the effects of heated water discharge into the marine environment.
• The public participation process is alleged to have been legally insufficient. groundWork claims that the draft environmental impact assessment (DEIR) was not subject to the required 30-day public participation, documents were password-protected or removed from the website, and extensive changes made to the Final Environmental Impact Report (FEIR) were not subjected to further consultation as required by Regulation 23(1)(b) of the EIA Regulations.
• The project's socio-economic assessment is criticized for being defective. It allegedly ignores the economic value of 'blue carbon' services provided by mangroves and seagrass, the impact of noise on fisheries and tourism, and the long-term financial risk of locking the country into an expensive 20-year power purchase agreement for gas.
• Expert analysis by Michelle Fournet indicates that the EIA failed to quantify baseline ambient sound levels and failed to model sound propagation specifically for the Richards Bay site, relying instead on inapplicable data from Ghana. This lack of site-specific modelling prevents an accurate assessment of impacts on marine mammals and prey species.
• The document asserts that expanding natural gas infrastructure is incompatible with the global goal of limiting warming to 1.5°C, as outlined in the UNEP Global Methane Assessment. It argues that the project's high methane and CO2 emissions would be counterproductive to South Africa's climate commitments and the Paris Agreement.

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. 14/12/16/3/3/2/2007): RICHARDS BAY. https://cer.org.za/wp-content/uploads/2021/08/groundWork-Responding-statement-on-Karpowership-Richards-Bay-EA-Appeal....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. 14/12/16/3/3/2/2007): RICHARDS BAY. n.d. https://cer.org.za/wp-content/uploads/2021/08/groundWork-Responding-statement-on-Karpowership-Richards-Bay-EA-Appeal....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. 14/12/16/3/3/2/2007): RICHARDS BAY |url=https://cer.org.za/wp-content/uploads/2021/08/groundWork-Responding-statement-on-Karpowership-Richards-Bay-EA-Appeal....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. 14/12/16/3/3/2/2007): RICHARDS BAY}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2021/08/groundWork-Responding-statement-on-Karpowership-Richards-Bay-EA-Appeal....pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }