Environmental authorisation to develop an offshore gas and condensate field between Mossel Bay and Cape St Francis.

The Draft Scoping Report says up to seven drilling campaigns will take place "over 6 years" (p. 204) and, in the same section set, "up to seven campaigns over 6 years" (p. 184), but elsewhere states up to seven campaigns "over ~11 years" (p. 8, p. 39) and gives a construction period of about 11 years in the project timeline (p. 185). The length of the drilling and construction period affects how long noise, vessel traffic and discharges continue, so the difference matters.

You may wish to ask the Department of Mineral and Petroleum Resources to require a single, corrected drilling and construction schedule in the Final Scoping Report, and to state which figure the specialist studies will use.

The Draft Scoping Report variously describes the development as about 75 km offshore at the closest point (p. 5, p. 37, p. 178), more than 65 km offshore (p. 11), more than 95 km offshore (p. 494, p. 505), 96 km to 150 km offshore (pp. 102 to 103), about 150 km offshore (p. 395) and about 160 km from shore (p. 462, p. 500). Some of these distances are used to justify excluding studies, for example the visual and health assessments were screened out partly on the basis of distance (pp. 102 to 103).

You may wish to ask for the distances to be reconciled, and for confirmation of which distance was used to justify excluding the visual impact assessment and the health impact assessment.

The Draft Scoping Report gives the Port Elizabeth Corals Marine Protected Area as less than 2 km from the Production Right area and the Southwest Indian Seamounts Marine Protected Area as 12 km away (p. 61), but later states that the closest offshore Marine Protected Area is the Southwest Indian Seamounts at about 19 km south of the project area, with the closest coastal Marine Protected Area at about 44 km (p. 347). Distances to protected areas are used to judge risk from noise, discharges and spills.

You may wish to ask for the correct distances to each nearby Marine Protected Area, with the source and measurement point stated.

The Department of Forestry, Fisheries and the Environment screening report of 6 August 2026 rates Agriculture as Very High, Plant Species as High and Palaeontology as High, while the report of 22 June 2026 for the same project rates Agriculture as High, Plant Species as Medium and Palaeontology as Medium (Appendix B pp. 7, 23 to 24). Neither screening report contains a development footprint: both state "No development footprint(s) specified" (Appendix B p. 6, p. 22), which means the ratings are indicative only. The main report reproduces only one of the two sets of ratings (p. 101).

You may wish to ask why two screening reports with different ratings exist for the same application, and request that a screening report based on an actual mapped development footprint be generated and included.

The terrestrial specialist surveyed the onshore route once, from 27 to 29 July 2026, in winter, and states that floral identification was limited by season and that a threatened species walkdown "MUST be conducted during flowering season (September to November) following sufficient rains" to find additional plant species of conservation concern (Appendix F pp. 14, 15, 34, 36, 48). A full Black Harrier nest assessment is also still outstanding and must be done in the July to September breeding season (Appendix F p. 51). Roughly 33 further plant species of conservation concern are expected in the area (Appendix F pp. 64 to 65).

You may wish to ask that the flowering-season plant walkdown and the Black Harrier nest assessment be completed and made public before the Impact Assessment Report is finalised, rather than left as a pre-construction condition.

The heritage specialist identified nine conservation-worthy shell midden and stone age sites inside the Option 1, 1a and 2a landfall corridors, plus further graded sites as close as 18 m and 25 m from Option 2a (Appendix G pp. 8, 10 to 11, 25, 47 to 48). It states that realignment "is unlikely to avoid all sensitivities entirely" given the density of material, and that Option 3, which runs inland, is the most preferred from a heritage point of view (Appendix G pp. 8 to 9, 24). The terrestrial specialist, by contrast, ranks Option 3 third and prefers Options 1, 1a and 1b (Appendix F pp. 49 to 52), so the heritage and biodiversity preferences point in different directions.

You may wish to ask how the competing heritage and biodiversity route preferences will be weighed, and request that the reasons for the final route choice be published before the decision is taken.

The Draft Scoping Report identifies gas and condensate spills, pipeline rupture and well blow-out as the main unplanned events (p. 12), but the hydrocarbon spill modelling, the well blow-out modelling and the flowline and pipeline leak modelling are all deferred to "the next phase of the ESIA" (p. 223, p. 260, pp. 515 to 517). The extended area of influence for a spill is therefore not yet known and is "to be confirmed via spill modelling" (p. 275). Until that modelling is done, no one can say whether the St Francis Bay coastline could be reached by a spill.

You may wish to ask that the spill modelling results, including the modelled reach of a worst case blow-out toward the Eastern Cape coast, be published in full and be open for public comment before any authorisation is decided.

The Draft Scoping Report states: "There is currently insufficient information available for the assessment of impacts and identify appropriate mitigation at the Scoping Phase" (p. 483), and the preliminary mitigation measures in Table 8-4 are explicitly not yet informed by specialist input (p. 484). Greenhouse gas emissions have not been calculated (p. 130), and the significance ratings for every impact are deferred. This means the public is being asked to comment before the scale of any impact is known.

You may wish to ask for confirmation that the Draft Impact Assessment Report and Environmental Management Programme will carry a full 30 day comment period with public meetings in the Eastern Cape coastal towns, as set out on p. 123.

The onshore pipeline under Option 1 passes through Critical Biodiversity Area 1 and a Critically Endangered ecosystem, would clear 300 m2 or more of indigenous vegetation, and would be built within 32 m of a watercourse (pp. 54 to 55). The Draft Offshore Oil and Gas Sector Plan is quoted as saying the need for "any offset and other prohibitions will be investigated as part of the ESIA" (p. 86), and the terrestrial specialist says offset mitigation "may be required for high impact activities" in High Site Ecological Importance areas (Appendix F pp. 50, 59). No offset detail, ratio or receiving site appears anywhere in the Draft Scoping Report.

You may wish to ask when the offset investigation will be completed and whether the offset proposal will be published for public comment before a decision.

The Draft Scoping Report states that the onshore gas pipeline may be classified as a Major Hazard Installation under the Occupational Health and Safety Act, to be confirmed by a Quantitative Risk Assessment (p. 69, p. 496), yet describes that assessment as a "screening-level QRA" in terms of SANS 1461 (pp. 519 to 520). A formal Major Hazard Installation risk assessment is said to be required only before construction (p. 496). The pipeline is planned at up to 150 bar to 200 bar design pressure and passes near the Nautilus Bay and Springerbaai estates (p. 249, Appendix G p. 27).

You may wish to ask whether a screening-level risk assessment is enough to support route selection, and request that the full Major Hazard Installation risk assessment be completed before the authorisation decision rather than after it.

The 30 day comment period runs from 14 September to 15 October 2026 (p. 41, p. 105), while the public open days were held from 14 to 22 September 2026, including St Francis Bay on 21 September, and the online meeting was on 1 October 2026 (p. 122, notice p. 5). The Draft Scoping Report itself notes that many interested and affected parties in the area have limited access to secondary and tertiary education, that there are very high levels of unemployment and poverty, and that "previous offshore projects have garnered widespread stakeholder concern" (pp. 113 to 116). The full Draft Scoping Report is available in English only, with the summary in Afrikaans and isiXhosa (p. 13).

You may wish to ask the Petroleum Agency SA and the Department of Mineral and Petroleum Resources for an extension of the comment period, giving your reasons.

Because the project is a gazetted Strategic Integrated Project, the Draft Scoping Report states that "the review and decision-making period afforded to the competent authority for the Final ESIA Report is 57 days" (p. 58). The Draft Scoping Report also notes that the split of the Department of Mineral and Petroleum Resources and the Department of Energy is "in process, but not yet finalised" (p. 40, footnote 5).

You may wish to ask how the shortened 57 day review period will allow full consideration of public comments and specialist findings, and which department will hold the decision if the split is completed in the meantime.

The Draft Scoping Report acknowledges that seabed communities and vulnerable species beyond the shelf break and outside surveyed areas are not fully characterised, that demersal fish communities beyond the shelf break are not fully characterised, and that there is no consolidated current information on most pelagic seabirds, turtles and cetaceans (pp. 280 to 281). It nonetheless concludes the baseline "is considered sufficient" (p. 281). Much of the development lies in deep water where these gaps apply.

You may wish to ask what additional survey work will be done in the Impact Assessment phase to close these gaps, and on what basis the baseline was judged sufficient.

Under Option 1 the gas would go to a gas receiving facility, for example the proposed Garden Route Gas-to-Power plant of up to 3 000 MW on Farm 419, which is the subject of a separate application by a different applicant and a different practitioner (p. 38, p. 179, pp. 459 to 460). That facility is excluded from the scope of this assessment (p. 462), although it is included as a reasonably foreseeable project for cumulative impact purposes (p. 520).

You may wish to ask how the combined effects of the offshore development, the pipeline and the power plant will be assessed, given that the two applications are being decided separately.

Visual, defence, radioactivity, traffic, geotechnical, health and seismicity assessments were all screened out (pp. 102 to 104), while the national screening tool listed visual, noise, radioactivity, traffic, geotechnical, health and seismicity assessments among those identified for the project and put the duty on the practitioner to motivate any exclusion (Appendix B pp. 6, 24). The terrestrial specialist also states that invertebrate species of conservation concern were "not covered by the scope of the SSVRs", even though the screening tool identified three invertebrate species of concern (Draft Scoping Report, p. 422; Appendix B pp. 9 to 10).

You may wish to ask for the motivation for each excluded specialist study to be set out in the Final Scoping Report, and for confirmation of whether invertebrate species of conservation concern will be surveyed.

The onshore pipeline may trigger water uses under sections 21(c) and 21(i) of the National Water Act, and the Draft Scoping Report says the need for a Water Use Licence or a General Authorisation "will be confirmed during the ESIA process" and that any application would be submitted to the Department of Water and Sanitation only after the Environmental Authorisation is granted (pp. 67 to 68, p. 492).

You may wish to ask for confirmation of whether a Water Use Licence will be required, and whether the water use application will be advertised for public comment in its own right.

The Draft Scoping Report records the Social and Labour Plan public participation process as running "14 July 2015 and 14 August 2025", which appears to be an error, since the surrounding text describes a one month process in 2025 and the plan was submitted to the Petroleum Agency SA on 30 September 2025 (p. 57).

You may wish to ask for the correct dates of the Social and Labour Plan consultation period and for the plan itself to be made available to interested and affected parties.

"No overall residual significance rating is given, as this is a Draft Scoping Report and impact ratings before and after mitigation are explicitly deferred to the Impact Assessment Phase (Assessment Report pp. 483 to 484). The only residual rating stated by a specialist is for the agricultural theme: \"overall low residual impact pre-mitigation and very low post-mitigation\" on the agricultural production ability of the land (Appendix H p. 25). The methodology provides for significance categories of Insignificant, Very Low, Low, Medium, High and Very High (Assessment Report pp. 533 to 534)."

"Yes"

• Online monitoring of produced water hydrocarbon content against the limit of 30 mg per litre under OSPAR Recommendation 2001 stroke 1 (Assessment Report p. 263)
• Post drilling ROV survey to scan for dropped equipment, with notification to SANHO of any seabed hazards (Assessment Report p. 510)
• Archaeological monitoring of all ground disturbing construction within the mapped sensitive coastal zone, regardless of the corridor selected, under a Monitoring Brief by a qualified archaeologist or heritage practitioner (Assessment Report p. 445; Appendix G pp. 8 to 9, 59 to 60)
• Monitoring Brief requirements to be determined through the Heritage Western Cape Work Plan process and to be incorporated into the EMPr (Appendix G pp. 8, 25, 59)
• Stop works protocol graded by field significance, with local pause for moderate significance finds and a stop works order for high significance finds such as dense in situ shell middens or human remains (Appendix G pp. 8, 25, 59)
• Chance Finds Procedures for archaeology, fossils and burials during construction, with work ceasing in the vicinity of a find and Heritage Western Cape alerted immediately (Assessment Report p. 445; Appendix G pp. 9, 13, 25 to 26, 60 to 61)
• Chance Finds Procedure recommended for maritime heritage under the SAHRA Minimum Standards (Assessment Report p. 524)
• Post construction monitoring of rehabilitated wetland and buffer areas (Assessment Report p. 431)
• Threatened flora species walkdown required before construction during the September to November flowering season following sufficient rains (Appendix F pp. 14, 34, 36, 48, 50)
• Full Black Harrier assessment including nest assessment required prior to construction if any intact fynbos is to be disturbed, to be conducted in the July to September breeding season (Appendix F p. 51)
• Annual reporting of carbon dioxide and methane emissions through the South African Greenhouse Gas Emissions Reporting System, and a Pollution Prevention Plan as greenhouse gas emissions are likely to exceed 0.1 Mt carbon dioxide equivalent (Assessment Report pp. 59 to 60)
• Metocean monitoring using 15 ADCP buoys over one year, and ongoing maintenance and inspection of subsea and onshore pipeline infrastructure during production (Assessment Report pp. 190, 184)
• Oil Spill Contingency Plan, Blow Out Contingency Plan, SOPEP under MARPOL Annex I Regulation 37 and Waste Management Plan to be developed, with a 500 m safety exclusion zone and a 5 nautical mile surveillance area around the CPF during operations (Assessment Report pp. 229 to 230, 259 to 260)
• Proof of insurance and global spill response service agreements, for example with OSRL, to be submitted to the regulator before activities commence, with a 10K capping stack resource held at Saldanha Bay (Assessment Report pp. 229, 274)
• Final mitigation measures to be refined with specialist input during the Impact Assessment Phase and set out in the EMPr (Assessment Report pp. 483 to 484)

• Project avoids all Marine Protected Areas: no MPAs occur within the Production Right application area or pipeline corridors, and no drilling discharges, commissioning effluent or produced water will be discharged within any MPA (Assessment Report p. 61)
• Avoid natural wetlands, seep systems and their 32 m buffers wherever practicable, and avoid locating construction camps, laydown areas, stockpiles, refuelling and batching areas in wetlands or buffers (Assessment Report pp. 430 to 431)
• Avoid High and Medium aquatic sensitivity areas, including delineated wetlands and their 20 m, 25 m and 35 m buffers (Appendix E p. 21)
• Route the onshore pipeline away from watercourse and wetland crossings where practicable, and prioritise Very Low, Low and Medium Site Ecological Importance areas and existing roads or cleared corridors (Assessment Report p. 416; Appendix F pp. 49 to 50)
• Mandatory avoidance in Very High Site Ecological Importance areas where no destructive development activities should be considered (Appendix F p. 59)
• Avoid known archaeological sites, graves, cemeteries, structures older than 60 years and areas of High or Very High palaeontological sensitivity where practicable, preferentially using existing disturbed corridors (Assessment Report p. 445)
• Apply 50 m no development buffers around OBS 3, OBS 8, OBS 9, OBS 11 and the formalised burial site OBS 4, and a localised buffer around the Doornfontein werf OBS 16 (Appendix G pp. 7, 9 to 10)
• Realign the landfall point away from identified coastal archaeological sites where Option 1, 1a or 2a is selected, noted as the first choice approach (Appendix G pp. 8 to 9)
• Screened out alternatives on environmental grounds, including a nearshore CPF location closer to the coast due to greater sensitivity of coastal and nearshore habitats, and onshore pipeline Options 4 to 7 due to environmental and social sensitivities (Assessment Report pp. 270 to 271)
• Apply a 200 m buffer around recorded individuals of the Vulnerable Leucospermum praecox in line with SANBI Species Environmental Assessment Guidelines (Appendix F p. 34)

• Bury the offshore pipeline within about 42 km of the coast to mitigate potential interaction with trawl fishing within the 90 m water depth contour, and design pipelines to be safely overtrawlable in established trawling areas (Assessment Report pp. 15, 372, 494)
• Use a horizontal directional drilled micro-tunnel of about 1.5 km for the shore crossing to pass beneath the coastal zone (Assessment Report pp. 8, 245)
• Minimise the number and width of unavoidable wetland crossings and locate them at narrow, stable or already disturbed sections, maintaining flow pathways and applying erosion and sediment control at valley bottom approaches (Assessment Report pp. 430 to 431)
• Use low toxicity drilling fluids, discharge more than 10 m below the surface, treat produced water to less than 30 mg per litre hydrocarbon content and use high efficiency flare burners (Assessment Report p. 485; p. 264)
• Return non aqueous drilling fluid cuttings to shore rather than discharging them at sea (Assessment Report pp. 204, 214)
• Vessel speed limits of a maximum 12 knots in transit, reduced to 10 knots within 25 km of the coast or when sensitive fauna are present, with collisions reported to the IWC database (Assessment Report p. 509)
• Soft start procedures for vertical seismic profiling sound sources, seabed surveys prior to drilling, vessel watch keeping and seawater intake grids (Assessment Report p. 484)
• Shield operational lighting where feasible to minimise light spill out to sea (Assessment Report p. 266)
• Ballast Water Management Plan and ballast water treatment system meeting Regulation D2 discharge standards, and antifouling coatings compliant with the IMO AFS Convention (Assessment Report pp. 502 to 503, 507)
• Waste Management Plan compliant with MARPOL 73 and 78, prohibition of oily water discharge above 15 ppm, no discharge of hazardous waste at sea, and segregation and fully traceable transfer of waste to licensed onshore facilities (Assessment Report pp. 266 to 267, 501)
• Pre plan helicopter flights to avoid low altitude flights below 762 m parallel to the shore (Assessment Report p. 505)
• Demarcate the approved development footprint, minimise vegetation clearance in the Endangered Hartenbos Dune Thicket, Albertinia Sand Fynbos and Southwestern Strandveld, and undertake plant search and rescue and topsoil stockpiling (Assessment Report pp. 486 to 487; Appendix F pp. 45, 50)
• Stakeholder engagement, appointment of a Fisheries Liaison Officer, SANHO charting and Notice to Mariners, and stakeholder notification at least three weeks prior to mobilisation, with 500 m safety exclusion zones (Assessment Report pp. 485, 504, 506 to 508)
• Traffic Management Plan during onshore construction, with abnormal loads moved under approved transport permits (Assessment Report p. 508)
• Where avoidance of coastal archaeological sites is not possible, a Work Plan approved by Heritage Western Cape covering pre construction detailed survey, sampling and salvage excavation before construction proceeds (Appendix G pp. 8, 25, 59)
• Onshore pipeline servitude reduced from 30 to 40 m during construction to 10 to 15 m during operation, and pipeline buried at 1.0 to 1.5 m depth (Assessment Report pp. 248 to 249)

• Rehabilitate disturbed wetland and buffer areas promptly through soil replacement, restoration of the natural surface profile and indigenous revegetation, with post construction monitoring (Assessment Report pp. 430 to 431)
• Progressive rehabilitation of the onshore pipeline footprint, with restoration mitigation required in Medium, Low and Very Low Site Ecological Importance areas following development activities (Appendix F pp. 50, 52, 59)
• Dune stabilisation during shore crossing rehabilitation, listed as a triggered activity for areas exceeding 10 square metres (Assessment Report p. 52)
• Rehabilitation, stormwater and erosion management and alien invasive species control as preliminary onshore controls (Assessment Report pp. 486 to 487)
• Repair or restore step of the mitigation hierarchy, for example shoreline clean up and rehabilitation (Assessment Report pp. 536 to 537)
• Well plugging and abandonment with wells sealed, plugged, tested for integrity and abandoned according to international best industry practice, with cement plugging creating an impermeable barrier (Assessment Report p. 510)
• Onshore pipeline to be disconnected, flushed, cleaned and plugged at both ends or repurposed at decommissioning rather than removed, to avoid renewed excavation and habitat impacts (Assessment Report pp. 184, 273)
• Financial provision under Section 24P of NEMA for progressive rehabilitation, decommissioning, closure and post closure, to be determined before the Environmental Authorisation is issued, supported by a Conceptual Decommissioning and Closure Strategy (Assessment Report pp. 55, 274, 528)

"The EAP does not yet conclude that impacts are acceptable after mitigation, because this is a Draft Scoping Report and it states that \"There is currently insufficient information available for the assessment of impacts and identify appropriate mitigation at the Scoping Phase\", with formal assessment deferred to the Impact Assessment Phase (Assessment Report p. 483). The EAP's preliminary position is that the Project is, in principle, aligned with a number of South Africa's energy security, economic development, resource management and just transition objectives, but that \"the ultimate determination of need and desirability will depend on the findings of the technical and specialist studies... and the balancing of environmental, social, economic and climate-change considerations\" (Assessment Report p. 177). The EAP further concludes that each NEMA Section 2 principle can be met subject to ESIA findings and EMPr implementation (Assessment Report pp. 169 to 173), and that the Project is capable of alignment with the objectives and principles of NEM:ICMA subject to the findings of the Impact Assessment Phase (Assessment Report p. 174). The EAP relies on the mitigation hierarchy of IFC Performance Standard 1, noting that High residual impacts must be reduced to an acceptable level to proceed and may trigger the need for compensation, offsets and project redesign, and that Very High residual impacts must be reduced below a critical threshold or the project must be fundamentally redesigned, relocated or discontinued (Assessment Report pp. 534, 536 to 537). Specialists give qualified acceptance: the aquatic specialist states the Project can be favourably considered provided the final layout is informed by the aquatic sensitivities and wetland crossings are minimised, and that \"No fatal flaws were identified\" (Appendix E p. 21); the heritage specialist states \"there is no objection to the proposed development from an archaeological perspective\" subject to the recommended buffers, Work Plan and Monitoring Brief (Appendix G pp. 9, 25, 59, 70)."

"Assessment Report pp. 15, 52 to 55, 59 to 61, 86, 184, 190, 204, 214, 229 to 230, 245, 248 to 249, 259 to 267, 270 to 274, 416, 425 to 426, 430 to 431, 434 to 435, 445, 483 to 490, 494 to 495, 501 to 510, 520 to 528, 533 to 537; Appendix E pp. 15, 19 to 21; Appendix F pp. 14, 34, 36, 45, 48 to 52, 59; Appendix G pp. 7 to 13, 24 to 26, 58 to 61, 70; Appendix H pp. 19 to 21, 25"