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Concerns and Questions

Caveat: This submission is not final or exhaustive due to a lack of information provided by Rhino and SLR, their process, literature and application.

Concern 1. I am concerned that the Exploration Licence Rhino Oil & Gas / Resources is seeking will, if granted, permit the holder extensive rights and permissions over and above those which they have admitted to, or which they have divulged to the inhabitants of Thabo Mofutsanyane district and other stakeholders.

Questions

In light of this, please divulge all permissions for which Rhino or its agents and affiliates has applied and any that will automatically be granted in terms of the Exploration Licence, regardless of whether or not they have been specifically applied for?

Please provide a copy of documents relating to Rhino’s application and any additional information that fully discloses Rhino’s goals and intentions, especially including those they have omitted from public meetings or literature.

Please provide evidence that their full Right to Know in relation to the Exploration Licence and its full ramifications have been fully explained to the inhabitants of Thabo Mofutsanyane district.

Concern 2. I am concerned that representatives of the Free State Department of Water Affairs, Dept of Environment, Dept of Land Affairs, Dept of Agriculture Forestry and Fisheries, Dept of Rural Development and the Department of Health, were not formally present at the meeting in Clarens on 6 December.

Questions

Were representatives of all the above Provincial Departments invited to attend?

If so, please name who was invited, with their designations?

Please provide evidence of this.

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If they were not invited, please explain why?

Concern 3. I am concerned that representatives of the Dihlabeng Local Municipality were not formally in attendance at the meeting in Clarens on 6 December.

Questions

Were any representatives of the Dihlabeng Local Municipality invited to attend this meeting?

If yes, please provide their names and designations.

Please provide evidence of this.

Concern 4. Advertising & Publicity. I am concerned about the manner in which the Rhino / SLR information sharing / public meeting was advertised to all stakeholders. In the interests of full disclosure to and trust building with Thabo Mofutsanyane communities, I am concerned that all the relevant stakeholders - including but not limited to landowners, PDA communities, parties excluded by the Digital Divide and affected individuals - were not correctly and timeously notified.

The process did/does not meet the correct standards required for authentic public participation.

In which media and other recognized platforms - such as community halls, local radio, loud hailers, libraries, schools, police stations etc. – was advertising placed?

In what languages was this advertising and publicity conducted?

For how long - please give dates - was this advertising and publicity conducted?

Concern 5. Education & Information. I am concerned about the lack of education and information initiatives in Thabo Mofutsanyane district - including among, but not limited to, elderly and rural people, individuals and groups disadvantaged by the Digital Divide and those with recognized literacy and language challenges - to fully and objectively inform stakeholders about the potential environmental, social and economic impacts stemming from the proposed petroleum-related exploration and extraction, with a view to empowering them to exercise their Constitutional “Right to Know”.

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The process did/does not meet the correct standards required for authentic public participation.

Questions

What efforts, sincere in both the letter and spirit of the Constitutional “Right to Know”, have been made by Rhino, SLR or agents of either, to objectively educate and inform the inhabitants, whether full time residents or part time, of Thabo Mofutsanyane district, about the proposed petroleum exploration and applications for mining and extraction and delivery of minerals of whatever nature?

Please describe and provide evidence any such education and information initiatives.

Concern 6. Notification. I am concerned about the negligent manner in which Rhino, SLR Consulting and/or agents acting on its behalf notified the inhabitants of Thabo Mofutsanyane district (full and/or part time) - including but not limited to, elderly and rural people and individuals and groups disadvantaged by the Digital Divide and those with recognized literacy challenges - about the highly complex series of processes and applications required by this proposed project. The process did/does not meet the correct standards required for authentic public participation.

Concern 7. Scheduling of Meetings. I am concerned that the selection of the times and dates for meetings was not done via a recognized and approved process of consultation with each of the relevant communities in Thabo Mofutsanyane district. Meetings were scheduled during the working week, at times of day when it was / is very difficult for people with work and childcare commitments to attend, during an extremely busy period of the working year for farmers, business owners and households. In addition, the scheduling of meetings leaves very little time for people to respond with questions and concerns within the 14 December deadline. The process did/does not meet the correct standards required for authentic public participation.

Questions

Please confirm, if any, how and by what consultative process Rhino, SLR Consultants and / or their agents will reschedule their stated agreement to re-schedule information sessions/public meetings?

Please name the decision-making entity/individuals.

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Please describe the reasoning and motivation behind their choice of dates and times.

Concern 8. I am concerned that, given the inconvenient schedules and poorly advertised meetings held in the Thabo Mofutsanyane district, the information sharing opportunities should be reconvened in order to be an inclusive and fully informed process for all stakeholders, including but not limited to disadvantaged communities and groups; the elderly; rural people; individuals and groups disadvantaged by the Digital Divide and those with recognized literacy and/or transport challenges. The process did/does not meet the correct standards required for authentic public participation.

Concern 9. I am concerned about the misleading language and the omission of crucial facts in literature and presentations distributed and presented by SLR and Rhino, with regard to the potential dangers stemming from extraction and delivery of unconventional fuels and other mining and mineral extraction activities. The process did/does not meet the correct standards required for authentic public participation.

Concern 10. GHG calculations. I am concerned that, should exploration be approved, and result in extratraction of coal bed methane or any other mining or petroleum related opportunities, the air and water quality in Thabo Mofutsanyane district will be severley compromised, and GHG will escalate in this region and further afield. Questions Please provide the full report for calculations of GHG emissions related to this project:

The exploration phase. The scoping phase. The extraction phase. The delivery phase.

With regard to the initial exploration, how many flights will be conducted over Clarens?

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How many flights will be conducted over the surrounding municipal district of Dihlabeng? How many flights will be conducted over the whole of Thabo Mofutsanyane? What size airplanes will be used? What type of airplanes will be used? Will pilots be employees of Rhino Oil & Gas/Resources or contracted on an ad hoc basis? Should the exploration licence be granted, please name the contracting company that will be used in the exploration flights. To reach Clarens and the surrounding district, what distances will planes be transported from the airbase where they are permanently stationed? Please give the same information for Dihlabeng?

Please give the same information for Thabo Mofutsanyane? To reach Clarens, and the surrounding district, what distances will manpower be transported from the homes where they are permanently stationed? Please give the same information for Dihlabeng?

Please give the same information for Thabo Mofutsanyane? To reach Clarens and the surrounding district, what distances will equipment be transported from the airbase where they are permanently stationed? Please give the same information for Dihlabeng?

Please give the same information for Thabo Mofutsanyane? How much fuel will be used in the flights over Clarens and the surrounding district?

Please give the same information for Dihlabeng? Please give the same information for Thabo Mofutsanyane?

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Concern 11. I am concerned that any mining, hydraulic fracturing, or other types of oil and/or petroleum-related extraction and delivery can dislodge naturally occurring heavy metals and radioactive materials and other contaminants. The safe disposal of effluents and other liquid wastes associated with these activities is a significant threat given their large volumes, typically high levels of contaminants and pollutants and the movement of water and air through natural systems as well as via manmade infrastructure such as pipelines.

Questions

What are the public health implications should any of the above exploration activities be approved and subsequent extraction proceed?

Please name all the chemicals used in the

extraction preparation delivery

of coal bed methane, coal, oil, mining or other petroleum products, which will be used should the Exploration Licence be approved and extraction of any of the above subsequently result.

How many chemicals are used in all of the above extraction and delivery processes, from start to finish?

Please describe with supporting documents and reports, what are the proven short-term effects of each of these chemicals on human health?

Please describe with supporting documents and reports, what are the proven medium term effects of each of these chemicals on human health?

Please describe with supporting documents and reports, what are the proven long-term, lasting and permanent effects of each of these chemicals on human health?

Please describe with supporting documents and reports, what are the proven short-term effects of each of these chemicals on animal health?

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Please describe with supporting documents and reports, what are the proven medium term effects of each of these chemicals on animal health?

Please describe with supporting documents and reports, what are the proven long-term, lasting and permanent effects of each of these chemicals on animal health?

Please describe with supporting documents and reports, what are the proven short-term effects of each of these chemicals on plant health?

Please describe with supporting documents and reports, what are the proven medium term effects of each of these chemicals on plant health?

Please describe with supporting documents and reports, what are the proven long term, lasting and permanent effects of each of these chemicals on animal health?

Please describe with supporting documents and reports, what are the proven short-term effects of each of these chemicals on soil health and quality?

Please describe with supporting documents and reports, what are the proven medium term effects of each of these chemicals on soil health and quality?

Please describe with supporting documents and reports, what are the proven long term, lasting and permanent effects of each of these chemicals on soil health and quality?

Please describe with supporting documents and reports, what are the proven short-term effects of each of these chemicals on health and biodiversity of insect species?

Please describe with supporting documents and reports, what are the proven medium term effects of each of these chemicals on health and biodiversity of insect species?

Please describe with supporting documents and reports, what are the proven long term, lasting and permanent effects of each of these chemicals on health and biodiversity of insect species?

Please describe with supporting documents and reports, what are the proven short-term effects of each of these chemicals on the health and biodiversity of bird species?

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Please describe with supporting documents and reports, what are the proven medium term effects of each of these chemicals on the health and biodiversity of bird species?

Please describe with supporting documents and reports, what are the proven long term, lasting and permanent effects of each of these chemicals on the health and biodiversity of bird species?

Please divulge on what precedents answers are based?

Please describe with supporting documents and reports, what are the proven short-term effects of each of the chemicals used for extraction and delivery on water quality of :

Groundwater Runoff Aquifers Wastewater Surface water

Please describe with supporting documents and reports, what are the proven medium term effects of each of these chemicals on water quality of


Please describe with supporting documents and reports, what are the proven long term, lasting and permanent effects of each of these chemicals on water quality of


Please describe with supporting documents and reports, what are the proven short-term effects of each of these chemicals on air quality in the surrounding atmosphere?

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Please describe with supporting documents and reports, what are the proven medium term effects of each of these chemicals on air quality in the surrounding atmosphere?

Please describe with supporting documents and reports, what are the proven long term, lasting and permanent effects of each of these chemicals on air quality in the surrounding atmosphere?

Please divulge with supporting research documents how far air quality is impacted around an extraction site?

In documents provided to people who specifically requested them, SLR/Rhino states “Natural gas comprises mostly methane and while it is

a hydrocarbon, it is a relatively clean, environmentally friendly form of

energy”.

How does Methane compare to CO2 and other Greenhouse Gases?

. Concern 12. I am concerned about the spread of chemical pollutants should exploration result in extraction.

Questions

Please clarify specifically how Rhino or its agents or any subsequent purchaser of the extraction rights, proposes to effectively prevent the spread of chemical impurities and pollutants into air and water systems, given that these elements are naturally and mechanically shared across great distances?

Concern 13. I am concerned that should Rhino locate any form of exploitative minerals or resources, they will sell the rights to another entity. In this event, I am concerned that any consultative public processes, objections, petitions or similar that communities in Thabo Mofutsanyane might engage in with Rhino and its affiliates or agents, will be null and void.

Questions

Please clarify in detail Rhino’s intention once it succeeds in gaining an exploration licence, and once it locates reserves of any of minerals or resources named or un-named in literature supplied at the Clarens meeting of 6 December?

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To what legal, social, moral, economic and environmental accountability will Rhino, its agents or fellow-companies be held once they on-sell the exploration rights to a third party?

Concern 14. I am concerned that the suggestion of job creation resulting from the discovery of any minerals, petroleum and/or unconventional fuel resources is false and misleading. It would be profoundly cynical on the part of Rhino, its fellow companies and agents including SLR, if unsubstantiated hope were planted in the minds of the people of one of South Africas poorest and least literate provinces, where grinding poverty is a daily reality.

Questions

Please specify what unskilled jobs any resulting project/s will bring to Thabo Mofutsanyane district?

How many unskilled jobs will be created in the Thabo Mofutsanyane district as a whole?

How many unskilled jobs will the project bring to Clarens specifically?

How many unskilled jobs will be created in the Dihlabeng municipal area?

Will these unskilled workers become permanently employed by Rhino, its agents or the compnay/ies that may purchase the extration rights from Rhino?

Please specify what and how many skilled and professional jobs will be created in Clarens specifically?

Please specify what and how many skilled and professional jobs will be created in Dihlabeng municipal area?

Please specify what and how many skilled and professional jobs will be created in Thabo Mofutsanyane district as a whole?

Will these posts be filled from local talent pools?

If yes, please provide evidence that the required skills sets and professionals currently exisit among the current residents of Dilhabeng and Thabo Mofutsanyane district?

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Will these professionals, drawn from this local talent pool, become permanently employed by Rhino, the new owner of the extraction rights, their agents or contractors?

If these questions cannot be answered with any degree of certainty, please justify why this completely un-proven, and very likely untrue, notion is included verbally, in literature and presentations ?

Concern 15. I am concerned about the deliberate cloud of mystery surrounding Rhino Oil & Gas as a company. In a country that values transparency in politics and business, and in a legal environment that upholds the values of truth, justice and the “Right to Know”, it is perfectly legitimate for the people of Thabo Mofutsanyane to be fully informed as to the company details of Rhino Oil & Gas/Resources and its related companies and affiliates, since it proposes to pursue exploration which could ultimately – whether or not Rhino itself is involved in any future extraction – impact, seriously damage or destroy their health, livelihoods, properties and natural environment. Rhino Oil & Gas will recognize that the spirit of the law is as much a factor as the letter. Phillip Steyn’s arrogant and dismissive attitude in public forums is evidence of Rhino’s lack of goodwill and the absence of good faith towards the people of Thabo Mofutsanyane and those further afield potentially impacted by contaminated water and air originating in Thabo Mofutsanyane and KZN, which is linked to the Thabo Mofutsanyane systems.

Questions

In light of the above:

Rhino Oil & Gas is advised by a Public Relations / Reputation Management entity. Please provide the name and details of this entity.

Please provide the name and details of Rhino SA’s parent company/ies.

Please provide the name and details of Rhino SA’s parent holding company/ies.

Please provide the name and details of Rhino SA’s subsidiaries.

Please provide the name and details of Rhino SA’s shareholders.

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Please provide the names and details of Rhino SA’s Board of Directors.

Please provide the names and details of Rhino SA’s executive.

Please provide the names and details of Rhino non-executive members.

Please name all the directors (executive and non-executive) and shareholders of Rhino Oil & Gas Exploration SA and other countries (USA , Europe, Far East, Africa etc.) from the year of inception to date.

Please provide copies of Rhino Oil & Gas/Resources’ Annual Report from the year of the company’s inception to date.

Concern 16. I am concerned about the risk of “pragmatic” environmentalism. SLR Consulting is undeniably influenced by the commercial nature of the relationship with its client Rhino Oil & Gas or its agents or affiliates, and is therefore unable to guarantee genuine objectivity in its environmental surveys and associated reporting. Where communities under threat feel that their quality of life, livelihoods properties and health may be in jeopardy, or that their perfectly legitimate concerns are not given recognition and do not carry weight in the discussion space, it is understandable that, through no fault of the residents of Thabo Mofutsanyane, a climate of distrust will develop between the licence applicants, their environmental consultants and the affected communities.

Questions

Have SLR and/or Rhino or their affiliates or agents clearly and truthfully declared their exploration and post-exploration objectives to the people of Thabo Mofutsanyane?

What assurances and proof does SLR and/or Rhino or their affiliates or agents provide that their environmental reports and studies are/will be genuinely ethical and objective?

Will SLR and/or Rhino or their affiliates or agents commit to a genuinely transparent, trust building process prior to and during the applications and other processes involving Thabo Mofutsanyane?

If yes, please describe by what means SLR and/or Rhino and/or their affiliates or agents intend to implement this transparent and trust building process?

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If no to any of the above, please explain the justifications for failing/refusing to do so?

Concern 17. I am concerned that all those reliant on water originating from KZN and Thabo Mofutsanyane district for personal use or their livelihoods, be fully informed about the potential risks stemming from the well-documented risks of contamination and pollution of air and water due to chemicals that may/will make their way into air and water systems feeding into the wider system, should mining, conventional or unconventional fuel extraction occur in Thabo Mofutsanyane.

Questions

Have all those that use water originating from KZN and Thabo Mofutsanyane district, been fully informed about the proposed project, and the potential risks to the health and wellbeing of human, animal, plant and insect life and biodiversity that may result from the above activities in the Thabo Mofutsanyane district?

If yes, via which media and recognized platforms (including community centres, municipalities, town halls, schools, local newspapers, television, radio, libraries, loud hailers and other means) was this national information/publicity campaign conducted?

In which languages was this multi-provincial information/publicity campaign conducted?

For how long was this multi-provincial information/publicity campaign conducted?

Caveat: This submission is not final or exhaustive due to a lack of information provided by Rhino and SLR, their process, literature and application.

BirdLife South Africa is a partner of BirdLife International, a global partnership of nature conservation organisations.

Member of IUCN (International Union for Conservation of Nature).

Reg No: 001 – 298 NPO

PBO Exemption No: 930004518

Jonathan Booth

Advocacy Officer

Policy & Advocay Programme

BirdLife South Africa

[email protected]

14/12/2018

SLR Consulting

PO Box 1596

Cramerview

2060

Attention: Matthew Hemming

Email: [email protected]

Dear Matthew Hemming,

Rhino Oil and Gas Exploration South Africa (Pty) Ltd APPLICATION FOR AN EXPLORATION RIGHT

FOR PETROLEUM AND GAS ON VARIOUS FARMS IN THE FREE STATE & KWAZULU-NATAL (346 ER)

BirdLife South Africa recognises the need for economic development, including responsible resource

extraction. We do not, however, support developments that may have a significant negative impact

to the country’s biodiversity and important water source areas.

With regards to the prospecting application, BirdLife South Africa notes the following:

That the size of this prospecting application of substantial;

That it is in close proximity to many forms of Protected Area (both current and soon to be

declared), and in some cases may overlap with existing Protected Areas;

That the area hosts many endangered and critically endangered species and ecosystems; this is

reflected by the prospecting area either bordering or directly overlapping with the following

Important Bird and Biodiversity Areas: Rooiberge-Riemland; Golden Gate Highlands National Park;

Sterkfontein Dam Nature Reserve; Maloti Drakensberg Park; Spioenkop Nature Reserve; Murphy's

Rust; Alexpan; Chelmsford Nature Reserve; Grasslands.

That a large proportion of the prospecting area is within Strategic Water Source Areas that mostly

feed into the Integrated Vaal River System, and which are critical for the supply of water to the

Gauteng region, South Africa’s most important economic area that already faces severe water

risk;

That the entire major river network on the western side of the water shed (i.e. water that flows

into the Vaal system) is classified as Critically Endangered due to its highly degraded state arising

from multiple pressures that are already exerted on this river system (see Appendix 1).

Further, we also note that there is extensive evidence of fracking having severely detrimental impacts

on ground and surface water due to the use of fracking fluid in drilling operations, and that many other

detrimental ecosystem impacts have been observed in the fracking process.

mailto:[email protected]



Reg No: 001 – 298 NPO


The value of this region from both an ecological and water supply viewpoint cannot be

underestimated. If prospecting resulted in gas reserves being found and drilling operations

proceeding, Rhino Oil and Gas would be placing one of South Africa’s most important Strategic Water

Source Areas under severe risk – and this is an area that is already highly impacted and is unlikely to

be able to withstand further impacts without incurring severe ecosystem impacts and having a

detrimental impact on the ability of the area to produce clean water.

With regards to the Upper Wilge region specifically, BirdLife South Africa has invested many years of

work and significant funds into declaring a Protected Environment (PE) on privately owned farmland

that has immense biodiversity and water value (the location of the site and Strategic Water Source

Areas is shown in Appendix 1). Land owners have long been committed to this process and the

Intention to Declare the Protected Environment will soon be published, after which a public

consultation phase begins. Should this prospecting application/Rhino Oil and Gas obstruct this

Protected Environment declaration in anyway, it would not only be to the detriment of significant

conservation efforts made (time and money) but would also have a significant impact on the ability of

South Africa to reach its Protected Area Targets (as per the National Protected Area Expansion

Strategy), conserve critically important ecosystems and endangered species, and to conserve its

Strategic Water Source Areas.

This prospecting application places one of our major conservation investments at risk. We therefore

request that you actively engage with BirdLife South Africa on this prospecting application, and the

treatment of the proposed Upper Wilge Protected Environment, going forward. We will avail ourselves

to meet with you on the matter at any time.

Yours sincerely,

Jonathan Booth

Advocacy Officer: Policy & Advocacy

BirdLife South Africa



Reg No: 001 – 298 NPO


Appendix 1.

The below image shows the location of the Upper Wilge Biodiversity Stewardship Site (soon to be

declared a Protected Environment), Strategic Water Source Areas, and the Conservation Status of

Major Rivers.

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