To whom it may concern,
As a person interested in and concerned with the issue of shale gas mining I formally register as an interested and affected party and herewith submit comment on the environmental management plan (EMP) of (Bundu Gas and Oil Exploration (Pty) Ltd) as distributed by Golder electronically
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The limitations of work and instructions that Golder (The consultants) received from the applicant (Bundu Gas and Oil Exploration), as outlined in Appendix A, makes it clear that a narrow brief was provided and that a full analysis of potential negative impacts have not been completed. It is also stated that where information was included from the previous
EMP process and documents, it is assumed that such information was in fact correct. The previous EMP document contained various flaws of significant magnitude, and the simple extrapolation of data from that EMP into the current offering does little except to entrench the original flaws. Formal comment submitted by I&A parties during 2010/2011 contains more detail of the flaws in the original EMP.
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The government has stated that exploration under “normal” circumstances could take place, but that regulations would need to be finalised before fracking can take place. The problem, however, is that baselines, environmental assessments, data storage and many other facets which are covered in the draft regulations will take place during normal exploration, therefore not necessarily according to the regulations, as they have not been finalised. It is nonsensical to proceed with exploration or for that matter to try and complete an EMP based on regulations that do not address the final results of the very process that the EMP is supposed to deal with and when the regulations have not been completed yet.
The EMP document would need to be aligned with the requirements in the regulation
(which are still currently in draft form). For example, if “well” casings or plugs are to be installed, it should be subject to the requirements in the fracking regulations – it therefore does not make sense to permit normal exploration or approve an EMP without the fracking process being properly dealt with in regulations, which must then result in a more specific and appliacble EMP being submitted in public.
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No venting or flaring of wells during exploratory drilling is mentioned or provided for in the
EMP document.
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Landowners have not all been contacted yet. (It is also not clear whether further attempts have been made to contact the remaining landowners that Bundu did not contact in the previous EMP process)

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Descriptions are generic, incomplete and shallow in many parts, as an example (one of many):
“The identified drilling area would be nominally cleared of vegetation to reduce fire risk and ensure safe passage across the site for core drilling operations.” o What is the size of the area that will be cleared? o What is the size of this area? Is this in addition to the well pad? Etc. o What is the application of this word ‘nominal’? What is it to mean to different people? Is ‘nominal’ the same to a biologist, a farmer, a miner, a tourist and a paleontologist?
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The hydrogeological model and baselines must be completed within an appropriate radius before core drilling, seismic surveying or any other invasive exploration technique is used, to ensure that water quality has not been compromised before baseline measurements are taken.
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It is stated that hydraulic fracturing would not take place during this first phase of exploration, but it is not clear whether any other well stimulation techniques are to be used to determine the prospectivity?
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In the document it is stated that “The final choice on drilling method will be determined at the time that a drilling contractor is appointed based on the availability of equipment at that time.” o The drilling method needs to be determined up front and the environmental management plan needs to take that into account to furnish decision-makers with sufficient and accurate information and for the development of a meaningful EMP.
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It is stated in the document that: “Drill muds will be prepared on site. Drill muds for exploration drilling operations are likely to be either barite or bentonite based. Muds will circulate to plastic lined sumps excavated on site..... When the borehole has reached its targeted depth and drilling stops the sumps will be cleaned and residual material disposed of at an appropriate waste disposal site. This will be the responsibility of the drilling contractor.” o The exact chemical compounds to be used during core drilling, the expected/measured chemicals compounds in the drilling waste/cuttings need to be verified. Sufficient groundwater baseline testing (with a sufficient radius) needs to be completed before any drilling (whether it is core drilling or exploration wells) starts. o Plastic lined pits are not safe for a number of reasons and are not according to industry best practices – better storage methods should be used

o Waste disposal is integral to the drilling and exploration process and requires far more attention than this. Have any appropriate sites been established/ located to accept the waste? What are the expected classifications of the waste, taking into account potential radioactivity? How would waste be transported? What volumes of waste are expected? o The drilling contractor responsible for waste disposal? The applicant appears to seek an opportunity to pass its legal liabilities in this issue on to a third party who may well turn out to be a small operator with no resources to deal with the effects of pollution, remediate and pay fines. No. The Contractor can and should also be held liable, but jointly and severally with the applicant. This must be a standard applied to every agreement and a condition of any licences issued. This principle is lacking from the flawed proposed fracking regulations that were copied from those suggested by the American drilling Industry as a means to self-regulate.
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The document states that “Drill crews will bring potable water to site sourced commercially or from the municipal system” o How will water be brought on site? Pipes, trucks, etc? o Has permission been sought from the municipality? Failing local availability of water, what other options are available? o Please note that landowners are not allowed to sell water and it could be subject to a water use license.
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The document states that: “The benefit to be derived through gathering critical geological information necessary to confirm or disprove the potential of the Karoo geology to yield gas is important. It will allow rational planning to be carried out for future exploration, should areas proved to be prospective. It will also provide early indications on potential gas yield which will allow economic development opportunities associated with the potential of locally produced gas to receive more structured and rational consideration.” o Several other factors would influence whether a decision would be rational or not, not simply the outcome of the exploration process. Rational planning also depends on the interpretation of data and motives, mandates and incentives of decisionmakers. o In many shale plays in the USA, initial estimates after exploration have been consistently and dramatically reduced even during the production phase, whuich has superseded exploration. This makes the point that some data from exploration around assumed sweet spots doesn’t prove in the Karoo would not necessarily deliver accurate information on the potential gas yields.
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The description of groundwater is very brief. The lack of data on groundwater and especially the lack of recent data referred to highlights the need for a comprehensive, strategic approach to baseline monitoring. The necessity of a qualitative and thorough

baseline study (over a sufficient radius around drilling locations) cannot be emphasised enough.
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The document states that: “It is reasonable to assume that, given the rural and undeveloped nature of the land within the exploration rights application area, the area can be assumed to be a clean air environment in its current state.” o This is unacceptable. Air quality monitoring needs to be carried out before drilling commences (diesel generators are mentioned to be used on site). It is not sufficient to include assumptions in the EMP document that could be verified by desktop or field research.
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Perhaps the most problematic statement in the EMP document is the following:
“No material impact on groundwater quality or yield is thus anticipated. The impact of conventional geological drilling on groundwater yield and groundwater quality is consequently assessed to be of low significance. Existing measures are adequate to
provide protection to the resource. Even in the event that there was localised impact on a local borehole that reflected as either reduction in groundwater quality or groundwater yield this impact would be reversible from the point that casing was installed.” o This statement is not backed up by scientific facts and is contradicted by experiences in the USA as well as in South African history, including the well-known polluting incident during the 1960’s that Soekor was responsible for. o Furthermore, all well casings would fail over time, potentially leaking fluids into groundwater. Safety cannot be guaranteed.
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Waste should not be stored in a near-by town
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The document states “all groundwater boreholes and surface water sites within a 2 km radius of the exploration borehole must be sampled; Follow-up groundwater and surface water monitoring at quarterly intervals after decommissioning of the drilling site for a period of 12 months (four monitoring events).” o How were these requirements decided on? o The radius should be bigger for most and especially certain sites, depending on variables such as dolerite o Post-decommissioning monitoring (and monitoring of well casing pressure) should continue for many years to follow, not merely 1 year. Security should be provided for long-term remediation in case of well casing failure and groundwater contamination.
The current version of the EMP document does not provide assurance, or scientifically verified proof of successful prevention or mitigation measures to prevent negative impacts on communities and the environment, especially taking into account that full-scale shale gas exploration, including fracking, would follow after the completion of this phase of the exploration programme.

I hereby object to any process advancing shale gas exploration in South Africa, given the recorded negative impacts on communities and the environment, as well as the lack of sufficient information, research and investigation regarding the potential implications of shale gas exploration and production in South Africa.
I would like to please be informed of any further processes or steps surrounding this issue.
Yours Sincerely,
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Contact details:
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