Earthlife Africa is hosting (with partners) a series of meeting around
South Africa on the EIA for Nuclear -1, the legal issues, and a possible
legal challenge if the EIA is granted. The Legal Resource Centre will be
making a presentation at each of the meetings, and the idea is that
other organisations share their thoughts on the EIA. Please mark your
diaries for the following dates, formal invitation letters to follow
with venue details.

1) Johannesburg, 18th of July 2011
2) Durban, 22nd of July 2011
3) Cape Town, 26th of July 2011

Towards a nuclear-free future,

Tristen

–
Tristen Taylor
Project Co-ordinator
Earthlife Africa Jhb
Tel: 011 339-3662
Cell: 084 250-2434
Website: www.earthlife.org.za

As a registered stakeholder, the Environmental Assessment Practitioner (EAP) (GIBB) wishes to advise you of the availability of the Revised Draft Environmental Impact Report (EIR) for review and comment from 09 May 2011 to 23 June 2011 (i.e. 45 days).

Enclosed are (a) a summary of the Revised Draft EIR, (b) a Comment Sheet, (c) a letter announcing the availability of the Revised Draft EIR, and (d) e-mail cover in Afrikaans and Xhosa. The full version of the Revised Draft EIR (hard copy and/or CD) will be available at public venues, grouped per province, as detailed on Page 3 of the attached letter, as well as on the following websites:

NOTE: Readers of environment.co.za the documents mentioned above are available here:
Nuclear-1 EIA  Revised Draft EIR Letter to Registered IAPs _English
Nuclear-1 EIA Revised Draft EIR Executive Summary_2011
Nuclear-1 EIA Revised Draft EIR Letter to Registered IAPs_Afrikaans
Nuclear-1 EIA Revised Draft EIR Letter to Registered IAPs_Xhosa

-     Eskom’s website: www.eskom.co.za/eia under the “Nuclear 1-Generation” link
-     Arcus GIBB website: http://projects.gibb.co.za/ under the “Nuclear 1 EIA” link

Please note that comments can be submitted in writing in one of the following ways BEFORE close of business on 23 June 2011 (please note change in details):

-       By mail: GIBB Public Participation Office, Nuclear-1 EIA, P.O. Box 3965, Cape Town, 8000
-       By phone: 021 469 9180 (Office hours: Mon to Fri – 09:00 to 13:00 excl. public holidays)
-       By fax: 021 424 5571
-       By e-mail: nuclear1@gibb.co.za / nuclear-1@gibb.co.za

I&APs are invited and encouraged to attend the public meetings where the findings on the Revised Draft EIR will be presented and discussed.

Thank you to everyone who has participated in the EIA process to date and those who will take further time to review the Revised Draft EIR, submit comments and attend meetings.

Yours sincerely

The GIBB Nuclear-1 Public Participation Officer

FULL LIST OF DOCUMENTS (and links) ON THIS PROJECT ARE COPIED BELOW

10 August 2010

Having put the public at risk by failing for decades to address the radioactive Acid Mine Drainage (AMD) seeping into our drinking water, the Pelindaba Working Group is astounded that the National Nuclear Regulator has recently employed the services of a branding agent to “create a positive public image” and now also pleads poverty over funding a single meeting with key civic stakeholders.

The NNR has come under attack for failing abysmally as a regulator and unsuccessfully trying to put a lid on the growing problems of radioactive acid water threat to rivers, farming and drinking water[i]. It also dismisses growing public concern over the stock-piling of radioactive waste and radiotoxic releases into the Crocodile River at Pelindaba and the Atlantic Ocean at Koeberg among other sites.

The performance of the NNR should be judged on their fulfilment of their fiduciary function, namely to protect the public, property and the environment from nuclear damage. To protect their image is an inappropriate triviality which is of very little importance in comparison to the more serious alleged failures of the NNR.

NNR regulates the entire fuel cycle and is beholden to the nuclear industry

The NNR currently regulates the entire nuclear fuel cycle from uranium mine exploration to decommissioning and radioactive waste.

The public have a right to know what is being spent on at least the one branding agent – Zanusi Brand Solutions – whose employees falsely identified their company as “Zanusi Grand Solutions” to solicit an interview from nuclear monitor groups and then failed to phone back.  Zanusi lists DEAT and the SABC among their other illustrious clients.

In 2008, erstwhile Minister Alec Erwin squandered over R4m taxpayer funds by employing FreedThinkers to give nukes a “make-over” and to “turn anti-nuke activists into pro-nuke ambassadors” in his desperate bid to save the discredited PBMR nuclear white elephant. It seems the nuclear industry will stop at nothing to promote this industry against all odds. And, pro-nuclear propaganda in South Africa is set to intensify and be funded by taxpayers starting at schools.

NNR has addition marketing study running

To make matters worse, a second NNR-sponsored “tracking study” is being simultaneously conducted by JGR Marketing Resources which has for years been paid to report on “levels of satisfaction amongst its key stakeholders”. None of these reports were ever made public.

Neither company knew about the other. Neither company followed through on their planned interviews and showed more interest in views over the NNR’s logo, for example, than views over NNR’s handling of radiological issues.

Yet in February this year the NNR asked about 50 civil society groups for “an engagement meeting” and for discussion items, and indeed the NNR budget reflects substantial funding – almost R13 million or 10% of its budget – requested for “stakeholder management”.

To date the NNR has failed to respond to a growing list of questions and concerns that directly impact on public safety in Cape Town, Johannesburg and Pretoria from past and existing nuclear activities – past and present – from public groups and this week finally turned down a request for a mere scaled-down R6, 000 after months of negotiation to bring civil society stakeholders together for the meeting.

Why is critical information on failures of the NNR Act being withheld?

Stakeholders had also asked the NNR to provide details of a thought provoking talk by NNR senior lawyer Rodney Elk on the NNR’s legal challenges and difficulties with reference to the implementation of the National Nuclear Regulator Act.

The cotton-wool approach

This initiative is now in jeopardy as the NNR pleads poverty and suggests it meets with stakeholders individually which appears to have begun despite talks about national talks. This is nothing less than anti participatory ploy or cotton-wool approach similar to that used by the consultants on nuclear Environmental Studies to whitewash public sentiment.

Stakeholder groups are situated at each of the five coastal regions earmarked for nuclear reactors, as well as Hartbeespoort, Koeberg and the Namaqualand, site of South Africa’s nuclear waste dump.  In addition, Gauteng and North West host NECSA and most of the uranium mines.

Pelindaba Working Group is aware that the NNR holds lavish pro-nuclear related conferences at upmarket venues that exclude civil stakeholders and spares no cost on the travel expenses of its executives – over R5,5m in 2008/9 and forecast at R7,640,080 in the 2011/12 financial year.

The NNR derives its income by issuing nuclear authorisations.  This compromises its ability to be an independent regulator, as opposing the granting of licences will impact directly on its ability to continue.  A body set up, with an independent funding model similar to the Water Research Council, would be more appropriate.

NNR lacks skills & is has missing funds

Its own annual reports reflect a dire shortage of skills and know-how at the NNR, while media reports and labour disputes indicate that significant funds have gone missing from its coffers.

The NNR has blatantly ignored requests by affected communities for critical information, including details on abnormal discharges of radioactive gases from Pelindaba emergencies, nuclear liability insurances, as well as the issuing of authorisations to hazardous nuclear vessels in our coastal waters and ports without at least requesting that our Mother City and her residents and businesses is insured against a potential nuclear disaster.

Last week residents around Pelindaba again reported hearing loud sirens but these were dismissed by the NNR and the Nuclear Energy Corporation as a “possible hoax” or someone else’s siren.

What of the legacy of nuclear waste stockpiles in South Africa?

The nuclear/radiotoxic legacy of this country is long standing.  Its most toxic impact is through radioactive acid water from mines throughout Gauteng, North West, Limpopo and Mpumalanga.  However, the impact of stockpiles of nuclear waste over the coming centuries is part of that legacy and cannot be assessed.  World-wide studies are pointing strongly to the danger presented by such waste to future generations, who may not understand the labelling because of the shifts in language alone.

It is imperative for this country to have a strong nuclear regulator, particularly in the face of new legislation which recently exonerated the Department of Environmental Affairs from dealing with environmental radioactivity – even in Environmental Impact Assessments. Instead law now places this duty solely at the door of the NNR, where such studies cannot be funded and would be retrospective to the granting of the Record of Decision.  Additionally, the NNR lacks capacity to do anything more than to acquiesce to all nuclear developments. This is clearly untenable as it puts communities at risk and, by default, forces the NNR to grant the licence.

Informed of the failures and inadequacies of the NNR, the EIA consultants Arcus Gibb reply that it is not their responsibility to assess the competence of the NNR.

South Africans need to awaken to the potentially dire consequences for generations to come of a weak[ii], corrupt[iii], incapable and inept[iv] regulator if nuclear expansion in South Africa is to be pursued, and indeed even if it does not.

Issued by:

>Dominique Gilbert

PELINDABA WORKING GROUP

083 740 4676

>Christine Garbett

CANE – Gauteng / Northwest Province

>Judith Taylor

Earthlife Africa Joburg

082 389 3481

[ii] See supporting document http://www.cane.org.za/wp-content/uploads/2008/03/Articles-on-National-Nuclear-Regulator-in-support-of-media-statement-published-on-CANE-10-Aug-2010.pdf

[iii] See separate document http://www.cane.org.za/wp-content/uploads/2008/03/Articles-on-National-Nuclear-Regulator-in-support-of-media-statement-published-on-CANE-10-Aug-2010.pdf

[iv] See separate document http://www.cane.org.za/wp-content/uploads/2008/03/Articles-on-National-Nuclear-Regulator-in-support-of-media-statement-published-on-CANE-10-Aug-2010.pdf

Document written by: Katja Vinding Petersen, Michelle Wcisel, Brenda Walters, Oliver Jewell, Alison Towner, in cooperation with the Trustees from Dyer Island Conservation Trust.

1 EXECUTIVE SUMMARY

Introduction

This document outlines the concerns of The Dyer Island Conservation Trust (DICT) with regards to the proposed establishment of a nuclear power station (NPS) at Bantamsklip. It also provides an overview of the research which the DICT deems necessary to be carried out prior to the establishment of an NPS as well as suggested monitoring programs during construction and operational phases.

Insufficient Baseline Data

DICT finds the current baseline data concerning this area and the ecosystem insufficient. In order to protect this area’s unique marine biodiversity, DICT calls for further research prior to the establishment of a NPS. Should the NPS project at Bantamsklip proceed, DICT would like to see more monitoring programs during the construction and operations phases.

Current Lack of Knowledge

The DICT is highly concerned that rare and endangered marine species will experience devastating impacts in relation to the NPS. Since there have been no studies carried out prior to the NPS concerning the marine animals i.e. sharks, fur seals, cetaceans, birds and fish species in the area, it is unknown to which degree the proposed site is of significance to these animals. Also, due of this lack of knowledge, DICT find the conclusions made in the EIA and in the Marine- and the Oceanographic Specialist studies highly questionable.

Consequential Damage to Ecosystem

It is not difficult to find examples from the past where developments have unintentionally destroyed factions of an ecosystem when information about that system was unknown until the damage was done. Any visitor to the Cape Agulhas region can describe a bio-diverse habitat that is as incredible as it is delicate.

That is why the DICT is calling for more research to be conducted in this region before further development occurs. Enabling us to better understand the intricate cycle of life in this region and further assess how future development may impact the area.

DICT calls for a document outlining actual research projects which will be carried out prior to and during the construction phase as well as during the operational phase. This document should also state the aim, the methods, duration of the projects, the expected results and how it is linked to other projects carried out in conjunction with the NPS. Eskom’s degree of commitment to the different research projects should also be stated.

Full document 67 pages available here.

Nuclear Protest at Thyspunt - Jeffrey's Bay

By Melanie Gosling
Environment Writer
Source

Just over 2 000 people marched through Jeffreys Bay on Sunday in protest against the multi-billion rand nuclear power station Eskom plans to build at the nearby Thyspunt.

While marchers converged on the local municipal offices where organisers handed over a memorandum, 14 chokka (squid) fishing boats dropped anchor just behind contestants in the Billabong international surfing championships and switched on their lights in support of the marchers.

The protest was organised by the Thyspunt Alliance, an umbrella body of several local resident, ratepayers, environmental, surfer and other organisations, who were joined by the chokka fishermen and a range of local people.

Allliance spokesperson Trudi Malan said on Sunday: “We thought we would not get many people because we were competing with the surfing and the rugby, but some of the surfers phoned and said please can we wait till the Kelly Slater heat had finished. We did and they all came rushing over. And some rugby fans told us they could always watch rugby again, but they may not have the opportunity to show their support again against a nuclear power station that would affect all their lives.”

Malan said the Alliance had purposely not entered the debate about the pros and cons of nuclear power, but were all opposed to siting a nuclear power station at Thyspunt. The Alliance was heavily critical of the environmental impact assessment (EIA) Eskom had commissioned, saying it had failed to address many biophysical issues of building the power plant at that spot.

Eskom had selected the site in the apartheid era with no input from the public. One of the criteria was that a site for a nuclear power station had to be at least 100km from any of the former “homeland” areas for security reasons.

“The EIA is an atrocious document. The biggest flaw is that it did not consider the chokka industry and there was no public participation in the site selection. During construction they will dump 6.3-million cubic metres of sand into the sea, which will kill the chokka industry. We do not want to jeopardise the development of our country, but we do not believe development should come at the expense of the environment,” Malan said.

Read full article

Say no to Eskom's Proposed Nuclear Reactors

ESKOM – ENVIRONMENTAL IMPACT ASSESSMENT (EIA: 12/12/20/944)

FOR A PROPOSED NUCLEAR POWER STATION AND ASSOCIATED INFRASTRUCTURE

REVIEW OF DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT

EXTENSION OF COMMENT PERIOD

As previously announced, an opportunity to review the Draft Environmental Impact Report (EIR) commenced on 06 March 2010 with a revised closing date of 31 May 2010.

Please be advised that the comment period has been further extended by an additional 30 days and the closing date for comment is now 30 June 2010 (117 days). You are, therefore, afforded the opportunity to use the extended period to further review the report and submit any additional comments.

Once the comments have been received a Revised Draft EIR, including its specialist studies, will be produced and placed at public venues for a further comment period of 45 days.

On behalf of the EIA Project Team, I should like to thank all those who have attended public meetings and Key Stakeholder Feedback Meetings held during the period 23 March – 25 May 2010, those who have already submitted comments on the Draft EIA Report and those who will take further time to review the reports and submit comments.

For additional information, please contact: Bongi Shinga or Dalene Murie at:

E-mail: nuclear1 @ acerafrica.co.za l  P O Box 503, Mtunzini, 3867 l Tel: 086 010 4958  l  Fax: 035 340 2232

Kind regards.

Yours sincerely

Ms Bongi Shinga

Public Participation Team

Say no to Eskom's Proposed Nuclear Reactors

ESKOM – ENVIRONMENTAL IMPACT ASSESSMENT (EIA: 12/12/20/944) FOR

A PROPOSED NUCLEAR POWER STATION AND ASSOCIATED INFRASTRUCTURE

REVIEW OF DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT

EXTENSION OF COMMENT PERIOD

As previously announced, an opportunity to review the Draft Environmental Impact Assessment (EIA) Report commenced on 06 March 2010 with a closing date of 10 May 2010 (a 66-day comment period). During the meetings held as part of the public review, various Interested and Affected Parties requested an extension of the review period.

After due consideration of the requests and legal requirements, it has been decided that the comment period will be extended by an additional 21 days. The closing date for comment is now 31 May 2010. You are, therefore, afforded the opportunity to use the extended period to further review the report and submit any additional comments.

On behalf of the EIA Project Team, I should like to thank all those who have attended public meetings and Key Stakeholder Feedback Meetings held during the period 23 March – 21 April 2010, those who have already submitted comments on the Draft EIA Report and those who will take further time to review the reports and submit comments.

For additional information, please contact: Bongi Shinga or Dalene Murie at:

E-mail: nuclear1@acerafrica.co.za l  PO Box 503, Mtunzini, 3867 l Tel: 086 010 4958  l  Fax: 035 340 2232

Kind regards.

Yours sincerely

Ms Bongi Shinga

Public Participation Team

The Department of Energy has finally issued the invitation for the much touted “broad consultation process” concerning its “IRP2” – basically the electricity / energy plan for this country for the next 20 years – a day BEFORE their deadline. This invitation arrived yesterday but that will not deter us from registering as stakeholders yet again to voice our opposition and reasons for opposition to the proposed inclusion of nuclear in the proposed energy mix for South Africa. But, WE NEED TO ACT QUICKLY.

For those who don’t know much about IRP2, there are web-links to articles on the IRP2 listed below to fill you in. But please ensure you register on the database of stakeholders ASAP for the pattern of recent times has shown that leaving it up to the next person or organisation, results in government turning its back on enlightened views to the detriment of this country’s future.

Over the past number of years we have relentlessly participated in all processes – EIAs, submissions to government or Parliament, presentations to energy regulators and policy makers, public hearings on energy policy etc only to find that pre-determined policies are riding rough-shod over democratic processes. Our petitions to the Speaker for Parliamentary debate over energy mix and nuclear policy have remained unheeded and indeed legislation enabling this lethal energy option has been Gazetted in spite of this. More recently the Energy Minister held a “nuclear stakeholders’” meeting in Cape Town to which she invited only ONE PERSON to represent the growing thousands of people in this country opposed to nuclear expansion while renewable alternative solutions remain the Cinderella option. Needless to say, his objections were dismissed and he was kicked out of the meeting.

You cannot allow the government to continue to be dismissive of whom it consults & recognise as stakeholders. Indeed the entire South African public is the biggest stakeholder!!

YOUR VOICE COUNTS. Please register! Help to drive the message that WE DO NOT WANT NUCLEAR ENERGY IN SOUTH AFRICA!

* * *

Herewith the invitation:

INVITATION TO REGISTER ON THE DATABASE OF THE DEPARTMENT OF ENERGY: IRP2

The Department of Energy hereby calls on all interested parties to register on its database of stakeholders for inclusion in the consultation process for the development of the IRP2 for Electricity 2010.

All interested residents, businesses, groups and sectors are requested to:

1.    Indicate their institution;

2.    Core business;

3.    Area of interest in the IRP;

4.    Preliminary position in their areas of interest; and

5.    Contact person/s and contact details

Interested parties are requested to submit the above-mentioned information to the office of the Director-General by the 20th April 2010. Such information may be faxed, emailed or posted.

Contact Person:

Ms Yolisa Mapekula

Department of Energy

Private Bag X 19

Arcadia

0007

Tel: 012- 444 4063

Fax: 012- 444 4505

Email: yolisa.mapekula@energy.gov.za

_____________________________________________________________________________

Some reading matter on the IRP2 and why your involvement is so important:

Cloud over power plan -Mar 19 2010

http://www.mg.co.za/article/2010-03-19-cloud-over-power-plan

Energy Department to publish IRP2 by June

http://www.engineeringnews.co.za/article/maqubela-2010-02-24

Inter-Ministerial Committee gives nod to IRP2 consultation plan – 31 March 2010

http://www.info.gov.za/speeches/2010/10040110051002.htm

Minister reassures business IRP2 will include broad consultation
April 7, 2010

http://www.busrep.co.za/index.php?fSectionId=552&fArticleId=5419352

Nuclear deal back on track-Mar 05 2010

http://www.mg.co.za/article/2010-03-05-nuclear-deal-back-on-track

SA outlines consultation process for 20-year energy plan

http://www.polity.org.za/print-version/sa-outlines-consultation-process-for-20-year-energy-plan-2010-04-01-1

GENERAL PRESS RELEASE

Immediate release

9 March 2010

“NUCLEAR 1”

DRAFT ENVIRONMENTAL IMPACT REPORT:

FATALLY FLAWED AND DESIGNED TO CONFUSE

The draft Environmental Impact Report (EIR) for a nuclear power station at the Bantamsklip site has been released for public comment, with a closing date set for 10 May 2010. Bantamsklip is situated near the Pearly Beach resort, 50 km east of Hermanus.

The Save Bantamsklip Campaign and its affiliates and associated organisations are happy to have been placed third on the list of priority sites, but the battle to have the Bantamsklip site removed entirely from the list is far from over. We assert that the Government has already confirmed their whole-hearted support for a “nuclear fleet” with all the ancillary nuclear fuel-chain components. Unless this commitment is opposed, we expect to see construction begin at Bantamsklip in ten year’s time, at the latest.

Like the Trojan House outside the gates of Troy, we believe that the wording of the Executive Summary of the draft EIR for “Nuclear-1″ has been designed deliberately to counter the highly visible and successful advance of the Save Bantamsklip Campaign. The idea behind the proponent’s propaganda is to sow discord and confusion in the ranks of the campaign by appearing to shift focus away to Thyspunt in the Eastern Cape as the first site.

Furthermore, the draft EIR suffers from a number of fatal flaws, such as the failure to specify the type of reactor envisaged for the site. How can we determine scientifically and accurately the environmental impact of a nuclear fission reactor when we don’t know what it is? It is rather like ordering a fleet of motor vehicles at an exorbitant cost, knowing absolutely nothing about the brand, its performance, nor its safety features!

We therefore call on all our supporters to redouble their efforts to defend and consolidate our position to have Bantamsklip and Groot Hagelkraal entirely removed from the list of potential sites.

We support and endorse the positive campaign of strengthening and deepening the drive for a World Heritage Site status and for the site to be taken away from Eskom and incorporated into the Agulhas National Park.

We ask all our supporters to study carefully the EIR and to register their objections to the report, available at www.savebantamsklip.org and to join us in a march in opposition to this proposal on Monday 26 April 2010. Further details will be released closer to the time.

John Williams

Chairman

Save Bantamsklip Association

082 923 1839

john @ savebantamsklip.org

www.savebantamsklip.org