By Hilton Thorpe (Kromme Enviro-Trust & Thyspunt Alliance)

Eskom has now applied to the National Nuclear Regulator (NNR) for a site licence for Thyspunt, but not yet for a plant licence. They will be applying in due course for a licence for a “Generation 111” Pressurised Water Reactor.


Assessment of the environmental impact of constructing a nuclear power station on the Thyspunt site has been in progress since 2008.    The Scoping Report was released in that year. The first draft assessment report was issued in 2010, followed by a second draft in 2011 and a third in 2015. The final Environmental Impact Report was released on 25th February 2016.

Responses from Interested and Affected Parties have been submitted, including a response from Hilton Thorpe on behalf of the St Francis Kromme Trust, the St Francis Bay Residents’ Association and the Thyspunt Alliance.

This response focuses on four aspects of the environmental assessment which are flawed to the point that they constitute a barrier to adequate evaluation of the site and are in fact misleading, intentionally or otherwise.

  1. Emergency planning procedures have not been taken into consideration in the site evaluation. The viability of the Thyspunt site in terms of emergency planning has been an issue since the Kouga Coast Sub-Regional Structure Plan of 1997.   Eskom has been well aware that this was the Achilles heel of the site, and its only solution has been an attempt to change the rules. Emergency planning is the responsibility of the National Nuclear Regulator, who has not played any role in the environmental impact assessment, and cannot play a role until such time as they receive an application for an operating licence. 
  2. A Social Impact Report is intended to assess the effect a development will have on the society in which it is located. The report supplied for the Thyspunt EIA is deficient in almost every respect and the competence of the relevant specialist is called into question. 
  3. One of the major deficiencies in the Social Impact Report is the assessment of the impact on what is known as ‘Sense of Place’. This is defined as “that distinctive quality that makes a particular place memorable to the visitor … the unique quality or character of a place”. The Thyspunt development will have a substantial impact on visitors’ – and residents’ – sense of place, but it is hardly mentioned in the report.
  4. Most importantly, the ‘impact rating criteria’ were originally structured in such a way that it was impossible for any impact, however damaging, to constitute a fatal flaw to the development proposal. This was acknowledged, but not implemented in the several revisions to the study, which remains deficient in all respects as a result.

The submission concludes that, in view of the flaws identified, the Thyspunt Alliance must demand that Department of Environmental Affairs reject the “Final Environmental Report”, and refer it back to Gibb to address the issues raised, in terms of NEMA Regulation 34.2(b).