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Some background information.

Belton Park Trading 127 (Pty) Ltd have lodged two applications for Prospecting Rights with the Department of Mineral Resources and Energy to undertake offshore prospecting activities. The first application was in October 2019 for sea concessions 14B, 15B, 17B (see Figure 1), and the second in January 2020 for sea concession 13C, 15C, 16C, 17C, 18C (See Figure 2).


Sea concessions 14B, 15B, 17B are located approximately 180km north of Cape Town, with inshore boundaries located 1km seaward of the coast between Elands Bay to the south and Strandfontein to the north, see Figure 1. The total line kilometres to be surveyed per concession are between 600 and 1200km, with a total footprint disturbance of approximately 12.24ha in total. Each exploration duration will be about four days per annum per concession area.

Sea concessions 13C, 15C, 16C, 17C, 18C are located 180km north of Cape Town, with inshore boundaries ranging from approximately 4km seaward of the high water mark along the coast north of Doring Bay (Concession 13C) to as much as 41km to the west of Rocher Pan in St Helena Bay (Concession 18C), see Figure 2. The total line kilometres to be surveyed per concession is between 600 and 1200km, with a total disturbance area of 20.4ha in total. The duration for each exploration activity is four days per annum in each concession area

Prospecting operations for both applications will be for minerals such as diamonds (specifically), gemstones heavy minerals, industrial minerals, precious metals, ferrous and base metals. Prospection operations entail:

  • Geophysical surveys: will use a vessel equipped with (i) a multibeam echosounder designed to produce high resolution digital terrain models of the seafloor in a wide swath below the vessel and (ii) a sub bottom profile that generated profiles up to 60m beneath the seafloor, to provide cross section views of the sediment layers

  • Drill sampling: drill penetrates sediments up to 12m depth above bedrock, fluidizes sediment with strong water jets, airlifted to the support vessel to be treated in the onboard mineral recovery plant. Oversized and undersized tailings are discharged back to the sea on site

  • Bulk (trench sampling): Depends on the above methods that establish the potential resource. Sampling is then conducted to confirm economic viability of the resource mining. Trenching is undertaken with a seabed crawler that is fitted with an anterior section system and controlled remotely to loosen seabed sediment with water jets in the crawlers’ suction. Sediments are then pumped to the surface for shipboard processing.


The area for proposed exploration lies within the southern zone of the Benguela current region characterised by a cool upwelling system. The nutrient-rich upwelled waters enhance primary production and support substantial pelagic fisheries. The potential impacts of these operations are mainly on marine fauna, where crawlers will damage and disturb the seabed, alter the sediment structure and localised disturbance of marine fauna due to noise and lighting. Oil spills pose a risk and would have immediate detrimental effects on water quality. Commercial and small-scale fishing will be impacted by the disruption of fishing operations, loss of access to fishing grounds and disturbance of fish populations which may impact livelihoods and a loss of income due to the decreased fishing effort.


The environmental impact assessment process as required by the NEM: EIA Regulations required scoping reports to be prepared for both the applications. These reports were made available electronically and in hard copies at various locations for review and comments by Interested and Affected Parties for 30 days between October-November 2019 and January-February 2020. Environmental Authorisation applications were also lodged at the same time as the draft scoping reports. In July 2020, a public participation meeting for the latter application took place virtually, due to the Covid-19 restrictions that did not allow for in-person meetings. The comments from these virtual meetings are available for viewing in the report. These projects are currently in the Environmental Impact Assessment phase and will be released for public comment when the draft report is completed.


Issues of Concern

One of the main concerns with these various offshore applications is the lack of effective public consultation which has been exacerbated by the covid-19 pandemic. There seems to be a perception that local communities and other interested and affected parties are not interested in and will not be affected by these developments since they are offshore and basically out of sight. This is a fundamentally incorrect perception since South African citizens, coastal communities and all users of the ocean environment are deeply concerned about what activities are planned for these marine areas. Coastal communities in particular, have relied on food and livelihoods from the sea for generations and have deep spiritual connections to the ocean. What happens in the oceans matters to them.


The coastal waters along this stretch of coast are particularly important for various commercial and small-scale fisheries. The public and local communities are increasingly concerned about the rapid increase in prospecting and mining approvals along the coast and in the marine environment. The recent approval to extend mining rights of the Tormin mine area on the coast north of the Olifants estuary along a pristine stretch of coastline, and the visible destruction of these beaches and coastal areas is a matter of public concern. Of specific concern in this instance is the vast number of overlapping mining activities in this region as well as the modus operandi of some of these mining companies. The Belton Park Trading December 2019 application does not reference the application two months prior to this one for the adjacent concessions on the landward side for precisely the same minerals. In the section on need and desirability it does not indicate that this second application would be jettisoned if the first application was successful, suggesting the companies intent to mine an extremely vast area, yet neither of the individual applications provide evidence of this if assessed on a case by case basis. The December 2019 application indicates the extent of the activity in this region. It indicates that exploration for oil and gas is currently undertaken in a number of licence blocks off the West Coast. Further it indicates that the sea concession areas overlap with Block 3A/4A for which PetroSA and Sasol are the licence holders. Although there is no current development or production from these sites however, a subsea production pipeline to export gas from the iBhubesi Gas Field to a location on the Saldanha peninsula and Grotto Bay has been approved for development by Sunbird SA. A number of proposed prospecting areas for phosphate are located off the West Coast, these overlap with the western edge of the proposed mining concession areas. A number of marine diamond mining right and prospecting concession areas are also located in proximity to the Sea Concession areas under this application. It is precisely the cumulative impacts of all of these current and future activities that are of concern.


Approval of these offshore prospecting applications that may well lead to mining rights together with the rapid increase in mining witnessed in the coastal environment undermines the vision and principles of NEMA and the NEM: Integrated Coastal Management Act of 2008 which requires ecologically sustainable development that balances maintaining ecological integrity with justifiable socio-economic needs.


The people of South Africa and coastal communities in particular, have a right to know about all proposals and plans for the marine environment and be given an opportunity to express their views and concerns. These concerns and inputs are required to be taken into consideration and addressed in the environmental assessment reports prepared by consultants as required by the NEMA: EIA Regulations of 2014. Furthermore, there is an urgent need for a more holistic and integrated approach to ocean planning as there is no overall vision of strategic plan for the west coast including the Offshore marine environment. Of concern is that all these applications are being assessed on an ad hoc basis and the South African public have no idea of what is being planned in their coastal and marine environment. There is an urgent need for a more strategic and systematic approach to ocean planning that involves the public in a transparent and meaningful way. The new Marine Spatial Planning Act 16 of 2018, provides a framework to enable this to take place but it is imperative that the pubic and local communities are involved in these planning processes.

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Figure 1: Sea Concession 14B, 15B and 17B, between Doringbaai (north) and Elandsbaai (south), off the West Coast of South Africa

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Figure 2: Location of sea concession 13C, 15C, 16C, 17C and 18C. 13C is adjacent to Strandfontein in the north while 18C is near Elandsbaai.

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