February 2008
To The Editor
Community and NGOs tired of Environmental Department: Fossil
fuels cost nation R4bn a year in healthcare!
Mr. Lukey’s comments that NGOs have not nominated people
to sit on government’s national reference group are
no surprise. groundWork and many other NGOs have, since the
early nineties, sought to critically engage in democratising
environmental governance.
In as much as environmental justice is now recognized in
policy, and in the National Environmental Management Act,
we have been successful. Recently, we have actively participated
in DEAT legislative processes that now seek to develop regulations
to give meaning to environmental justice. Our participation
has, however, been meaningless and a waste of funder’s,
and the DEAT’s money, and actively reverses the gains
we have made for the following reasons:
* We submitted detailed comments following the publication
of the National Framework on Air Quality, and we got no response
from the DEAT nor Mr. Lukey himself about our invitation to
meet to discuss the future of the process and our comments.
* We actively participated in the DEAT waste incineration
policy process and enriched the process with detailed submissions
(which included input from international technical advisors)
in comment on government’s plans to incinerate waste.
Our concerns have been ignored because they are not what Mr.
Lukey and his Department want to hear. During this ‘participation
process’ the DEAT bluntly stated to us that “we
do not have to inform you why we are not considering your
comments.”
Over the past two years we have asked the DEAT to provide
us with information on the cement industry and they refuse,
forcing poorly funded NGOs to have to undertake a costly and
lengthy PAIA process which was consistently stalled by the
DEAT with incomplete information followed by silence once
we have shown the flaws and requested the amendments. To date
the DEAT have not provided us with the complete documents
they are legally obliged to provide us with.
It is for all these reasons, Mr. Lukey, that we are skeptical
and reluctant to participate in the DEAT processes you speak
of and are extremely cautious as to how we approach your call
for ‘participation’. Our growing opinion is the
the DEAT use our participation to rubber stamp and justify
their decisions to the Minister because our law does not allow
for progress in legislative processes without broadbased stakeholder
participation.
We are growing tired of being used to this end and perhaps
might consider that it could be better to engage with the
DEAT on the fence line and in the courts of law. For one,
we will be building peoples’ awareness of the Department’s
inefficiencies and secondly, although it might take us longer
to achieve, we might get delivery of our constitutional right
to an environment that is not harmful to our health and well-being.
Regards,
S. (Bobby) Peek
Director
groundWork, Friends of the Earth, South Africa
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