CSIR Draft White Paper National Commercial Ports Policy Comments by CSIR(Environmentek/Transportek)

CSIR Comment 1: Policies  Reference is made a number of policies  Planning has undergone massive transformation over the past 5 to 7 years – moved from purely focusing on spatial aspects to integrating public participation, environment, and budgeting

CSIR Recommendation 1  National Environmental Management Act (Act No. 107 of 1998) (NEMA)  Local Government Transition Act (Act 209 of 1993)  Municipal Systems Act (Act 32 of 2000)  White Paper on Spatial Planning and Land Use Management (2001)  Integrated Development Planning (IDP) Regulations (draft at present) Include a discussion of Integrated Development Planning (Discussed in more detail in comment 6 & 7)

CSIR Comment 2, 3 & 4: Vision, Goals, Objectives & Principles  The vision statement does not refer to sustainability or sustainable development  Sustainability mentioned in Goals but not carried through into objectives and principles

CSIR Recommendation 2, 3 & 4  Ensure proactive integration of social, economic and biophysical environmental aspects during the early stages of port planning and throughout the port development cycle including the planning, design, construction, operation and decommissioning of port developments.  Ensure proactive communication and consultation with all port stakeholders early on in the port planning stages.  Ensure that strategic port planning is closely aligned with the integrated development planning process of the associated city.

CSIR Comment 5: Competitive position of SA commercial ports  Number of factors affecting the competitiveness of SA ports are discussed – environmental issues are excluded.  Case Studies: Port of Durban – Container Terminal Port Richards Bay – Coal Terminal Port of Saldanha – Oil Terminal

CSIR Recommendation 5  Add environmental constraints to the list of constraints (this will ensure that the issue is considered when considering competitiveness of SA Ports)

CSIR Comment 5 (2): Environmental Sustainability  A reference is made to “The Governments new policy on environmental management”. Correct reference:  National Environmental Management Act (Act No. 107 of 1998)  Environmental Conservation Act (Act No. 73 of 1989) Use of Environmental Management tools

CSIR Recommendation 5 (2) PORT POLICY PORT PLANNING PORT DESIGN PORT CONSTRUCTION PORT OPERATION SEA EIA EMP EMS Integration of Environment, Social and Economic Aspects Continuous improvement

CSIR Comment 6 & 7: National Development Strategy for Commercial Ports “This policy advocates port and city co- operation through planning structures that will be facilitated and enabling of that particular intent.  “…NPA as a planning and development co-ordination body”  “Ensuring that planning of each port is localised as much as possible…..”

CSIR Recommendation 6 & 7 Links between Port Planning and Integrated Development Planning:  Port planning should be closely linked to the IDP planning process as specified in the Municipal Systems Act (Act 32 of 2000).  The NPA of each port should be represented on the steering committees of port-city IDP processes.  Legal aspects governing port-planning processes should be investigated in detail.

CSIR Additional comments:  No mention of the moving South Africa Strategy  SADC – links between other ports and SADC ports policy

CSIR Conclusion  Integrating environmental and social issues throughout port policy, planning, construction and operation  Integration of port planning with city planning (IDP) into a single integrated Port-City Planning process