IMPACT ASSESSMENT CASE STUDIES FROM SOUTHERN AFRICA

Compiled by Paul Scherzer E&D Consulting Services Client: Telkom SA

SAIEA

Southern African Institute for Environmental Assessment

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ROUTING OF THE EASSy SUBMARINE CABLE, SOUTH AFRICA

Compiled by Paul Scherzer E&D Consulting Services Client: Telkom SA

ROUTING OF THE EASSy SUBMARINE CABLE, SOUTH AFRICA

Aims of the Project
Telkom SA operates existing submarine fibreoptic telecommunication cables in South African waters from two landing locations, one on the west coast and the other at Mtunzini on the east. The South Africa Far East (SAFE) submarine cable was landed at Mtunzini in 2001. The existing cable station and shore-based infrastructure at Mtunzini had capacity for an additional cable. Telkom SA proposed to land another cable, the East Africa Submarine System telecommunications cable (EASSy), on the main beach of Mtunzini. The aim of the proposed EASSy cable was to enhance telecommunication links along the east coast of Africa, as this region relies exclusively on satellite which is expensive and limited in capacity.

Brief description of the development and alternatives considered

Submarine telecommunication cables form a vital part of the global communications network. Fibre optic cables are essentially tiny glass fibres which transmit digital pulses converted by computers at

Figure 2: Illustration of cables and increasing levels of armouring each end of the cable. A typical lightweight cable has a 17 mm outer diameter and comprises a welded steel tube housing multiple fibre pairs in a stress-free environment. In order to protect the cable, depending on the level of risk, the number and diameter of armour wires surrounding the cable is increased, with a high strength double armoured cable having an outer diameter of approximately 45 mm (Figure 2).

Figure 1: Route of the proposed EASSy cable down the east coast of Africa.

SAIEA 2009

Compiled by Paul Scherzer E&D Consulting Services Client: Telkom SA

ROUTING OF THE EASSy SUBMARINE CABLE, SOUTH AFRICA

Brief description of the development and alternatives considered
The routing and laying of a submarine telecommunication cable is preceded by detailed planning involving market capacity and marine cable routes, as well as negotiation between various international telecommunication service providers regarding financial contributions and market share. In order to select the optimum route for a submarine cable a range of marine charts, regional bathymetric data, seabed topography and geology sources are consulted. Information must also be gathered from relevant government departments, telecommunication companies and other groups such as marine oil and gas companies. Due to the cost of laying and repairing cables at sea, route planning considers cable safety and aims to avoid, among other aspects, steep mountain slopes and deep trenches below the ocean, areas of heavy shipping and rocky eroding beaches as landing points. The greatest danger to communication cables is from bottom contact fishing methods performed by trawlers. For this reason Telkom stipulates a no trawling or anchoring zone for one nautical mile on either side of their submarine cables. An international cable company is appointed to undertake the planning and implementation of the entire cable. Once initial desktop routes have been planned a detailed marine survey is undertaken, particularly in shallower waters (less than 1,000 m deep) where the cable approaches the landing station. The purpose of the survey is to optimise the position and laying of the cable to avoid high risk areas and to finalise the design and protection required for the cable. A survey is then taken of an area approximately 1 km wide along the identified route, and thereafter the final cable position is optimised within this surveyed band. Mtunzini Importantly, one survey ship is contracted to undertake the survey for the entire cable and all the landing locations. Thus, due to the distances and costs involved, the survey is undertaken according to a programme that is relatively inflexible in terms of accommodating last minute changes or repeating parts of the survey to consider other locally proposed alternatives. Due to the fact that Telkom had an existing landbased cable station at Mtunzini with spare capacity, alternative landing sites were not considered for the proposed EASSy cable. However, one of the key stakeholder groups which objected to the laying of the initial SAFE cable at Mtunzini was the prawn trawling industry operating out of Durban. The SAFE cable traversed both the in-shore and off-shore trawling grounds and for various reasons at the time an alternative alignment to miss these trawling grounds was not feasible. A legal dispute between the Prawn Trawlers Association and Telkom occurred after the environmental authorisation process and laying of the SAFE cable.

Figure 3: Landing of the SAFE cable at

SAIEA 2009

Compiled by Paul Scherzer E&D Consulting Services Client: Telkom SA

ROUTING OF THE EASSy SUBMARINE CABLE, SOUTH AFRICA

Environmental setting
The KwaZulu-Natal prawn trawl fishery consists of two components: an inshore fishery, referred to as the Thukela Banks, and an offshore fishery (Figure 4). Trawlers can fish from March to August on the Thukela Banks and year round on the offshore grounds. Different species are caught at these respective grounds. Importantly there are few areas off the South African coast suitable for shallow water penaeid prawn trawling due to the very narrow continental shelf, particularly in the sub-tropical areas of northern KwaZulu-Natal which are the only areas warm enough to support a breeding population. The Thukela Banks fishing grounds support the southernmost commercial prawn fishery in the western Indian Ocean. Fishing rights had been allocated from 2006 to 2013 and were held by four fishing companies. However, general opinion was that the trawling industry was struggling to remain economically competitive due to reduced catches as a result of the closure of the St Lucia estuary mouth and cheap imports. The closure of the St Lucia estuary mouth was considered to be having a significant negative impact upon the shallow water penaeid prawn stocks found on the Thukela Banks, as this species is dependent on estuaries for their nursery grounds. The prawn species targeted on the offshore fishing grounds are species which are not dependent on estuarine habitats during their lifecycle and, thus, had not been affected by the closure of St Lucia. An important socio-economic impact was that the existing trawling companies were concerned that any additional loss of trawling grounds would further reduce the grounds and catches and, thus, the economic viability of the trawling industry. There are only specific areas off the KwaZuluNatal coast which are suitable for prawn trawling. Apart from the climatic conditions and sea-floor conditions suitable for prawns, trawling needs to occur in areas where there are no reefs which can snag fishing gear, and in areas large enough to make it economically and practically viable to trawl. It is not practical for trawlers to simply lift their nets over an obstacle, drop them again and continue. So the trawlers will not operate in an area that is too small to obtain a reasonable catch in one trawl. Figure 4: Prawn trawling grounds off KwaZulu-Natal For these reasons the trawl grounds, particularly the Thukela Banks, were identified as an

SAIEA 2009

Compiled by Paul Scherzer E&D Consulting Services Client: Telkom SA

ROUTING OF THE EASSy SUBMARINE CABLE, SOUTH AFRICA

Environmental setting
environmental and economic resource which, regardless of current catches and cheaper imports, remains an important resource for conservation. Thus, whilst the actual size and operation of a submarine cable has practically no impact on the actual prawns, the resource would be impacted if the cable route resulted in the grounds being divided up into sections too small to viably trawl.

EIA process followed

The EIA process went through a Scoping Phase followed by an Impact Assessment Phase. During the Scoping Phase, meetings were held with representatives of trawling companies to discuss the proposed cable route. Various concerns were raised that the cable would further dissect the Thukela Bank fishing grounds. Representatives provided specific coordinates of the fishing grounds. These positions were communicated to the client who in turn requested the international cable route team to consider an alternative route. An alternative cable alignment was considered and proposed.

Scoping Phase public participation From the outset, the client was concerned that appeals or legal disputes from the trawling industry would either delay environmental authorisation or project implementation. The process was therefore designed to ensure that the trawling industry was provided with maximum opportunity to comment and participate, and that off-shore cable route alternatives could be considered. In order to ensure that the best cable route alternative could be selected, the environmental consultant ensured that the process of stakeholder consultation would align with the programme of the international cable route team who were planning the routes and the marine survey. The consultant was well aware that once the marine survey was undertaken, no other offshore alignments would be considered due to the technical planning requirements and costs associated with a marine survey.

Specialist study The Oceanographic Research Institute was appointed to undertake a specialist study focusing on the impacts of different cable routes upon the trawling grounds and industry. The data used was the most accurate data available and consisted of 19,943 trawl deployments and catches between 2000-2006. This data had been recorded by the trawlers as per the requirements of their licences. The specialist study focussed on the potential loss of trawling grounds on both the Thukela Banks and offshore grounds for the original proposed

SAIEA 2009

Compiled by Paul Scherzer E&D Consulting Services Client: Telkom SA

ROUTING OF THE EASSy SUBMARINE CABLE, SOUTH AFRICA

EIA process followed
alignment and for the proposed realigned alternative (Figure 5). As both still impacted the trawling grounds an optimum route was identified that would have practically no impact upon the trawling grounds. In addition, the cumulative impacts of the existing SAFE cable, another submarine cable being planned by a separate telecommunications company, and the proposed EASSy cable, was investigated. In all calculations of trawl grounds and proportions of the total catch likely to be lost, the trawling industry was given the benefit of the doubt. For instance, delineation of the extent of the grounds and estimates of the minimum area they required for uninterrupted trawling were done conservatively in their favour. The specialist study was also tasked to do a retrospective assessment of the impact of the existing SAFE cable, to verify the extent to which that cable had actually impacted the industry. The number of trawl drops and size of catches made within the 1 nautical mile exclusion zone prior to laying the cable and after the cable was laid, were calculated.

Figure 5: Preferred and alternative EASSy cable alignments

SAIEA 2009

Compiled by Paul Scherzer E&D Consulting Services Client: Telkom SA

ROUTING OF THE EASSy SUBMARINE CABLE, SOUTH AFRICA

EIA process followed
Public participation during the Impact Assessment A key stakeholder workshop was held to which representatives from all the trawling companies were invited, regardless of whether they had recently been trawling or not. The aim of this workshop was to provide the trawling industry with an opportunity to discuss the draft specialist findings and proposed cable route alignments. Various perspectives and issues were raised during the workshop. The environmental consultant and specialist then undertook to further investigate and clarify the additional points, and produced a summary report for further comment by the trawling industry. These findings were then incorporated into the draft Impact Assessment Report, which was distributed for public comment. Certain representatives from the trawling industry took the opportunity to comment again. This feedback was responded to and both the comments and responses were incorporated into the Final Impact Assessment Report.

Main environmental impacts & issues

The issues relating to the loss of trawling grounds and impact upon the industry were complex and varied. For this reason two sections were specifically included in the report: one, highlighting the assumptions and limitations made during the assessment, and the other highlighting the difficulties associated with an accurate assessment. These difficulties related to interpre-ting the data and findings in the light of other unquantifiable factors, such as: this part of the grounds in comparison to other parts of the trawl grounds. Other factors such as current strength, skipper skill and crew working and rest times also play a role in determining fishing locations and efforts.

The importance of the inshore Thukela Banks fishing grounds relative to the rest of the fishing grounds, and the influence of the closure of the St Lucia estuary mouth on catches on these grounds. The influence of cheaper imports of the same prawn species on fishing effort on the Thukela Banks. The licensed trawling periods on the Thukela Banks had been reduced over the period for which data was available, from 12 months to only six months of the year. This influenced the relative contribution of the catches from

After careful consideration of the findings it was apparent that if trawlers continued to operate over and around the initial cable route proposed, as had occurred with the SAFE cable, there would be little impact upon the industry or the economic viability of the trawling grounds. However, when applying a applying a risk-averse and cautious approach from both technical and environmental perspectives, it was preferable that trawling did not occur over the cable and that the cable route selected should minimize its impact on the trawling grounds. Yet, a range of other factors still needed to be taken into account such as the findings of the final bathymetric survey, cable protection and length, feasible cable angles and turnsetc. which influence the cost and risks of different cable routes. These factors would influence the final

SAIEA 2009

Compiled by Paul Scherzer E&D Consulting Services Client: Telkom SA

ROUTING OF THE EASSy SUBMARINE CABLE, SOUTH AFRICA

Main environmental impacts & issues
alignment being investigated by the international cable team. For this reason the impact assessment report identified and proposed a wide corridor within which the cable would have minimal impact on the trawling grounds (Figure 6). The aim of the corridor was to allow the international marine working group to optimise the final alignment with respect to reef crossings, cost and other technical factors, while still avoiding the trawling grounds.

Decision making process

During the process the client, Telkom SA, as well as the international cable team, were open and willing to revise alternatives in order to minimise environmental impacts. The impact assessment did not recommend either the first or second desktop alternative identified by the client and proposed a corridor within which the client was willing to survey and further plan the cable route. The specialists were required to review the sections of the draft Impact Report dealing with their findings and the draft Impact Report was then peer reviewed by a registered Environmental Assessment Practitioner in another company. The final Impact Report received a positive Record of Decision from the authorities, authorising that the cable be laid within the proposed corridor. No formal appeals were submitted by stakeholders. During the decision-making process the international marine working group surveyed a final alignment for the cable that remained within the proposed corridor, even bending north to miss the extremities of the inshore trawling grounds. At the time of writing the cable was still to be laid.

Figure 6: Optimum cable corridor

SAIEA 2009

Compiled by Paul Scherzer E&D Consulting Services Client: Telkom SA

ROUTING OF THE EASSy SUBMARINE CABLE, SOUTH AFRICA

Main elements of excellence in this EIA
The clients recognition of the potential value of the environmental assessment process in optimising the project and reducing the risk of delays and additional costs. Telkom was willing to work with the assessment team to investigate and consider alternatives that would minimise negative impacts, and had an approach with affected stakeholders that sought to identify winwin solutions. The environmental consultants understanding of the technical planning process enabled the EIA process to be optimally aligned with it. Consequently the environmental findings were provided in me to influence technical decisions. Importantly, this alignment would not have been possible had the client gone ahead with the technical planning process prior to appointing the environmental consultant. Careful and detailed use of accurate specialist data made it possible to quantify potential impacts. Importantly, the assessment separated the potential socio-economic impact on the currently licensed trawlers from the potential loss of future economic resources which the trawling grounds represented. The data were interpreted conservativelywith the benefit of doubt going towards the environment. Furthermore, in assessing these impacts, the report did not profess to have neatly quantified the significance, but highlighted the reality that there were many variables and uncertainties that made impacts extremely difficult to quantify. All the assumptions and uncertainties were clearly highlighted, and a retrospective assessment of the impact of the existing cable helped to guide interpretation of the data. In the end a cautious approach was adopted. It proposed an alternative which minimised current socio-economic impacts and the long-term loss of a potential resource, while still providing the technical team with enough leeway to optimise design and cost factors. The key affected stakeholders were involved throughout and were provided with the opportunity to discuss findings and interpretations. They requested the assessment team to investigate further and clarify parts of the specialist findings, which helped to improve confidence in the results.

Lessons learnt
For an Environmental Impact Assessment to add value to a project, the key environmental issues, impacts and risks need to be identified and investigated in time so that they can influence technical planning and decisions. If projects are not timed and coordinated correctly, the technical planning process may proceed without environmental input, reducing the EIA to just another administrative requirement that the client must obtain. The more contentious and difficult an issue is to assess, the more careful the consideration of all factors must be, and the more stakeholder participation is required. An Impact Assessment Report should explain how the findings were interpreted, what assumptions were made, what uncertainties were identified, and how the final recommendation was influenced by these factors. This allows the thinking and interpretation behind the assessment to be understood by stakeholders.

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SAIEA 2009