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Draft White PaperNational Commercial Ports

PolicyComments by

CSIR(Environmentek/Transportek)

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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

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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)

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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

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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.

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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 TerminalPort of Saldanha – Oil Terminal

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Recommendation 5

Add environmental constraints to the list of constraints

(this will ensure that the issue is considered when considering competitiveness of SA Ports)

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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

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Recommendation 5 (2)PORT POLICY

PORT PLANNING

PORT DESIGN

PORT CONSTRUCTION

PORT OPERATION

SEA

EIA

EMP

EMS

Inte

gra

tion

of

En

vir

on

men

t, S

ocia

l an

d E

con

om

ic A

sp

ects

Continuous improvement

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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…..”

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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.

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Additional comments:

No mention of the moving South Africa Strategy

SADC – links between other ports and SADC ports policy

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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