Groundwater opinion on the proposed regulations for the exploration and production of onshore oil and gas requiring hydraulic fracturing technology, its related Minimum Information Requirement documents and the guideline for well decommissioning

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The document argues that current proposed regulations for unconventional oil and gas (UOG) in South Africa are insufficient, particularly regarding the exclusion of coalbed methane (CBM) and inadequate groundwater protections. It recommends expanding definitions to include all stimulation techniques, implementing strict setback distances to protect sensitive aquifers and towns, and requiring long-term monitoring of decommissioned wells for up to 50 years to prevent contamination.

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  • The proposed regulations focus almost exclusively on shale gas and hydraulic fracturing, failing to define or regulate coalbed methane (CBM) and the significant volumes of saline produced water associated with CBM extraction.
  • The author argues that using rainfall as a proxy for water availability in the Karoo is unreliable due to high spatio-temporal variability; instead, groundwater sustainable yields should be the primary guideline.
  • To prevent groundwater over-abstraction, the document recommends incorporating climate change impact assessments into hydrogeology studies to determine climate-adjusted groundwater recharge estimates.
  • The document proposes a comprehensive list of minimum setback distances to protect water resources, including 10km from existing municipal wellfields and towns without wellfields, and 5km from natural aquifer recharge areas.
  • Current regulations lack sufficient integration of surface water protection; the author recommends defining wetlands and establishing specific protection zones and setbacks for watercourses.
  • The author identifies a critical need for a 'fracturing fluid management plan' for every well to manage the entire lifecycle of chemicals, from sourcing and mixing to disposal and recycling.
  • Baseline seismic monitoring should be conducted for at least 24 months to identify hidden active faults that could be reactivated by fluid injection, using sensors in shallow boreholes (20–30m depth) to improve signal-to-noise ratios.
  • The guidelines for well decommissioning are criticized for lacking long-term monitoring requirements; the author suggests a monitoring timeframe of 50 years may be necessary due to the risk of well integrity failure.
  • The document recommends that decommissioned wells should never be abandoned but instead transferred to state custody (DMR / PASA / DWA) to ensure continuous maintenance and integrity monitoring.

Cite the original document

APA
Esterhuyse, S. (n.d.). Groundwater opinion on the proposed regulations for the exploration and production of onshore oil and gas requiring hydraulic fracturing technology, its related Minimum Information Requirement documents and the guideline for well decommissioning. Centre for Environmental Rights. https://cer.org.za/wp-content/uploads/2026/05/Esterhuyse_Groundwater-opinion_Final.pdf?x21779
Chicago
Esterhuyse, S. Groundwater opinion on the proposed regulations for the exploration and production of onshore oil and gas requiring hydraulic fracturing technology, its related Minimum Information Requirement documents and the guideline for well decommissioning. Centre for Environmental Rights, n.d. https://cer.org.za/wp-content/uploads/2026/05/Esterhuyse_Groundwater-opinion_Final.pdf?x21779.
Wikipedia
{{cite press release |last1=Esterhuyse |first1=S |title=Groundwater opinion on the proposed regulations for the exploration and production of onshore oil and gas requiring hydraulic fracturing technology, its related Minimum Information Requirement documents and the guideline for well decommissioning |publisher=Centre for Environmental Rights |url=https://cer.org.za/wp-content/uploads/2026/05/Esterhuyse_Groundwater-opinion_Final.pdf?x21779 |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@misc{esterhuysendgroundwater, author = {Esterhuyse, S}, title = {{Groundwater opinion on the proposed regulations for the exploration and production of onshore oil and gas requiring hydraulic fracturing technology, its related Minimum Information Requirement documents and the guideline for well decommissioning}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2026/05/Esterhuyse_Groundwater-opinion_Final.pdf?x21779}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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