JUDICIAL REVIEW – ENVIRONMENTAL AUTHORISATION FOR EXPLORATION OF OIL AND GAS GRANTED TO SASOL / ENI – MARINE ECOLOGY EXPERT INPUT

The report concludes that the environmental impact assessment (EIA) for exploration drilling in block ER236 was scientifically inadequate regarding anthropogenic noise. The author argues that the study's determination of 'minor' noise impacts is premature because it failed to include an acoustician on the team and ignored critical factors such as the effects on commercially important fish, prey species, and the physiological impacts on sound-sensitive taxa. Specific failures identified include the omission of Vertical Seismic Profiling (VSP) analysis, the lack of baseline soundscape data, and the failure to model sound propagation in the Indian Ocean, which could affect Marine Protected Areas (MPAs) and Critical Biodiversity Areas (CBAs) like the Protea Banks and the Sardine Route. The report also highlights risks to migrating humpback and right whales, as well as nesting sea turtles, and calls for the adoption of the precautionary approach as outlined in IWC Resolution 2018-4.

• The Marine Ecology Study associated with the EIA failed to include an acoustician on the assessment team, which the author deems necessary for a comprehensive impact assessment of noise.
• The report identifies 13 critical failures in the study, including the failure to consider impacts on commercially important species and prey species, and the omission of Vertical Seismic Profiling (VSP) analysis.
• The study's reporting of decibel (dB) units is inconsistent and lacks essential descriptors such as reference pressure, how sound pressure was computed (e.g., RMS, peak, or peak-to-peak), and the bandwidth used.
• The EIA underestimated drillship source levels; the author notes that a drillship measured in other literature was 1.5 times louder than the maximum loudness reported in the study.
• The study failed to establish a baseline soundscape for the region, making it impossible to assess how much proposed activities will increase ambient noise levels.
• The EIA's use of sound propagation data from the southern Namibian coast (Atlantic Ocean) to describe the site in the Indian Ocean is insufficient because sound attenuation is site-specific.
• Anthropogenic noise from the project may impact critical biodiversity areas, specifically the Protea Banks cold-water coral system and the Sardine Route fish migration corridor, both within approximately 30 km of the drilling location.
• The proposed drilling timeline (November to March) overlaps with the migration of humpback and right whales, potentially masking the 'acoustically cryptic' communication between mothers and calves.
• The report argues that the EIA failed to incorporate the precautionary approach of the International Whaling Commission's (IWC) Resolution 2018-4, which states that a lack of scientific certainty should not justify postponing cost-effective noise mitigation.
• Proposed mitigation measures in the EIA (hull cleaning and minimal low-altitude overflights) are inadequate; the author recommends ship speed reductions, convoying ships, and pausing operations in the presence of sound-sensitive species.

APA

Fournet, M. (n.d.). JUDICIAL REVIEW – ENVIRONMENTAL AUTHORISATION FOR EXPLORATION OF OIL AND GAS GRANTED TO SASOL / ENI – MARINE ECOLOGY EXPERT INPUT. Natural Justice. https://naturaljustice.org/wp-content/uploads/2021/06/DDS31-Fournet-Report.pdf

Chicago

Fournet, Michelle. JUDICIAL REVIEW – ENVIRONMENTAL AUTHORISATION FOR EXPLORATION OF OIL AND GAS GRANTED TO SASOL / ENI – MARINE ECOLOGY EXPERT INPUT. Natural Justice, n.d. https://naturaljustice.org/wp-content/uploads/2021/06/DDS31-Fournet-Report.pdf.

Wikipedia

{{cite report |last1=Fournet |first1=Michelle |title=JUDICIAL REVIEW – ENVIRONMENTAL AUTHORISATION FOR EXPLORATION OF OIL AND GAS GRANTED TO SASOL / ENI – MARINE ECOLOGY EXPERT INPUT |publisher=Natural Justice |url=https://naturaljustice.org/wp-content/uploads/2021/06/DDS31-Fournet-Report.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{fournetndjudicial, author = {Fournet, Michelle}, title = {{JUDICIAL REVIEW – ENVIRONMENTAL AUTHORISATION FOR EXPLORATION OF OIL AND GAS GRANTED TO SASOL / ENI – MARINE ECOLOGY EXPERT INPUT}}, institution = {Natural Justice}, url = {https://naturaljustice.org/wp-content/uploads/2021/06/DDS31-Fournet-Report.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }