The commentary period on Eskom’s applications for Nuclear licences for the two proclaimed new Nuclear sites closes on 29 August 2016. It is with urgency that OUTA appeals to the public at large to submit their comments to government by using the form below.
The fact that a matter of national importance was suspiciously hidden in Provincial Gazettes and limited newspapers, suggests a purposeful lack of meaningful public participation – especially when this matter is of significant importance to the public at large.
As a public interest organisation, OUTA is concerned at the errors in these Gazettes and other pertinent matters relating to this process. It is for this reason that we encourage the public to comment thereon in the form provided below, as a matter of urgency.
To assist the public, we have done the following:
- Provided you with a link to the respective Gazettes #3717 (found here) for the site at Thuyspunt and #7656 (found here) for Duynefontyn. Eskom’s applications to the National Nuclear Regulator (NNR) can be found here (Thyspunt) and here (Duynefontyn).
- A list of OUTA’s concerns (which it will include in its submission) are provided below the form.
- An e-mail form which makes it easy for the public to provide a submission to the correct recipient in authority is provided below.
We encourage the public to make a submission and if possible, to include their own specific reasons for objections or support of the contents in the gazettes. The public are also free to extract parts of OUTA’s list of concerns or points noted below the submit button, if indeed these resonate with you.
0 comments sent as of 12:00pm 2 September 2016
These are just a few of the concerns we believe are pertinent for comment to these Gazettes.
In OUTA’s opinion, these Gazettes are regarded as impractical and should be challenged for the following reasons:-
- The Gazette notice dated 8th August 2016, lists a 30 day comment period which ends on the 29th August 2016. This is a significant error in that it shortens the comment period by more than one week.
- In addition, while the National Nuclear Regulator Act 47 of 1999, requires an absolute minimum of 30 days for public comment and for the notices of the Gazette to be published in a minimum of two local newspapers, we believe that the Nuclear Energy issue and the sites of the Nuclear Energy Reactors is of significant cost and impact to the South African Society at large, that this matter requires:-
- More time for the public to provide comment on this matter.
- More detail about what type or nuclear rectors will be installed at these sites.
- The cost and size of the Nuclear Reactors to be built at the location(s).
- The impact of these Nuclear reactors on the the marine and inland environments.
- The core components of the application need to be included in the Gazette in order to provide the public with a minimum amount of information required to comment, such as Eskom’s eight page application to the Nuclear Energy Regulator (dated 22 February 2016), which should not have been left out of the Gazette, even though it was referenced to in a web site link.
- The decision to build these Nuclear Reactors precedes the entire decision on the ability of the nation to (a) affordability of the proposed Nuclear Energy Program and (b) the alternative energy solutions available to the public which may negate the need for the building of Nuclear reactors at these sites. Our concern here is that the decision or plan to build nuclear reactors on these sites may not be the right or may not have passed the constitutional muster of meaningful public participation, thereby placing this expenditure of a nuclear reactor site and building exercise into the space of a “sunk cost” situation and possibly a wasteful expenditure exercise, which South Africa can ill afford.
- The operations and processes are not explained.
- No studies or evidence within these submissions reflect any site-specific research to determine the possible socio-economic and environmental impacts of the planned Nuclear Reactor build at these locations.
- The draft applications are generic and very vague. In its site licence application, Eskom provides no detailed information on which the public are able to comment on.
- Prior lack of public consultation and participation on the Nuclear Energy matter has become a serious concern in that:-
- The public consultation has been almost non-existent when the size and economic impact of the project is deemed to be large.
- It is our understanding that Minister Joemat-Pettersson has signed a contract on 22 September 2014, with the Russian State Atomic Energy Corporation ROSATOM to provide South Africa with nuclear energy, without consulting parliament or the public on the matter. Only the president and a handful of ministers knew about it. Parliament was not consulted on this decision and in effect, this may result in a significant cost to the nation.
- In its current form, these applications do not address any safety concerns, which should be provided in this process and as is required in section 24 of the Constitution.
- An understanding of the sites’ geology is still very limited.
- South Africa is a water scarce country where economic growth and sustainability is dependent on the availability of water. This Gazette does not provide us with significant input or detail of the Nuclear Reactors water requirements, which is significant and pertinent to this application for public comment.
OUTA encourages all members of the public to participate by providing comments in response to BOTH Gazettes. While we believe the closing date of Monday 29th August 2016 to comment is incorrect, we urge the public to do so by the 29th August 2016, but if you have failed to meet this date, to continue submit their responses until 6th September 2016, which is 30 days after the 8th August 2016.
The more active we are as citizens, the more the authorities will be required to take note of the public’s questions and concerns on matters of such importance and impact on them.