Considering that the KZN coastal area has a high amenity value, with between 49.7% and 61.3% of activities undertaken by foreign visitors in KZN being beach related, it is staggering that there hasn't been a cost / benefit analysis of the offshore oil and gas development planned for its coastline for 2019. The costs of an oil-well blow-out on the tourism, recreation and leisure industries may be catastrophic yet the aspect of compensation to these sectors has not been dealt with at all. Studies worldwide show that oil spills generate coastal impacts that can last many decades.

Transparency is also needed with regards to Oil Spill Response, Planning and Capacity necessary for public health and welfare as well as that of the marine and coastal environment wrt oil + gas exploration planned for 2019 off the KZN coastline. Blowout management protocol for the ENI/SASOL project needs to be made public. Any deficit of technological expertise or resources or difficulty of effective co-ordination with all government or conservation agencies that have a statutory responsibility for some aspect of offshore oil and gas activities regarding incident management must be amended. The delegated National Incident Commander, along with the intended lines of responsibility for inter-agency efforts, should be made available for public engagement. The citizens of South Africa need assurance that incident management is fully informed and has capacity to deal with the latest technology, practices and risks associated with, and due to, the different geological and ocean environments being explored, prior to commencement of drilling.

There is significant concern over timeous response to a spill given the listed mitigations and rate of flow of the Agulhas current:
a. The recommended emergency equipment and team “who will be mobilized immediately” are based in Saldanha Bay 990 nautical miles and 4.1 days away ( travelling at 10 knots). Based on these delays hundreds of kilometres of ocean could be fouled before proper response is in place.
b. The capping stack which is supposed to “significantly reduce spill period” will be shore-based, at least 50km away from the drill sites, and will pose a logistical problem due to its tonnage and size in terms of transport to the drill site. It will take time to reach a deep-sea blowout.
c. Are localised emergency response teams ready? Is there are proper inventory of the necessary equipment and are the necessary teams available at a moments notice? Who will drive the tractor to close the mouths of the many estuaries to prevent oil from devastating already vulnerable wetlands? Etc.

- Please see additional concerns at:- https://oceansnotoil.org/2018/11/12/ono-objects/
- Regards structural weakness in protective environmental law with the repeal of EIA legislation for oil reconnaissance in RSA waters please see:- https://becomingvisible.africa.
- ERM (environmental consultants to ENI/SASOL) response to EIA comments can be found at:- https://drive.google.com/file/d/1numnepG2qfKzJP-aoNGLr9Q3Q2mZPDeo/view

Please can you investigate these issues for the sake of many livelihoods and the present and future biodiversity of our coastline. We look forward to your response.