groundWork Submits Comment on DEFF’s Notices to Fast-Track Environmental Assessment Processes
08 September 2020 - In response to a Public Notice calling organisations to engage with the DEFF, groundWork has prepared detailed comments on various Environmental Management Instruments. Our comments were delivered to the Director-General of the Department of Environment, Forestry and Fisheries (DEFF) on Friday 4th September 2020.
Public participation processes have not reached all the people and communities living in the affected areas. The greatest impact of fossil fuels and their infrastructure is felt by poor and marginalised communities. The proposed increase in gas pipelines, infrastructure and related activities, will result in increased risks and will impact negatively on human health, ecosystems and water resources.
Specialist studies and reports have been excluded from SEA processes. The oil and gas industry, worldwide, already contributes 71% to global greenhouse gas emissions. Gas development in South Africa will increase our greenhouse gas emissions and must not be falsely described as a source of clean fuel. Job creation within the industry has not been properly addressed. The development of gas pipeline infrastructure will not create sustainable jobs. Gas infrastructure will become redundant (and dangerous) in less than 20 years, while the lifespan of solar installations currently is 30 years.
The only reference to ‘liability’ (i.e. legal responsibility) in the Notice and related documents can be found in GN 836, Appendix 9, Declaration of the Proponent Commitment to Implement the Standard, which absolves the government of any responsibility. This means that the government is ensuring its own protection from any liability arising from the increased use of gas and gas infrastructure but is not offering any protection to its citizens. The ‘liabilities’ of gas companies, contractors and subcontractors within the supply chain have not been addressed. This means that the government has ensured that its liability to the public and the environment will not be included in any authorisation for any developer.
All risks to public safety and human health must be assessed. Attempts to fast-track environmental authorisation processes will add to the risks carried by people and the environment. The national web-based environmental screening tool for all new authorisation applications is flawed. If the DEFF’s screening tool is used to fast-track authorisation processes, this may not allow enough time for proper public participation, consultation, specialist studies and assessment of the above critical components. This will result in adverse impacts for which South Africa will be liable. South Africa’s Constitution requires ‘ecologically sustainable development’ which cannot be provided in a fast-tracked process that ignores environmental protection.