20th June 2007


1. The South African Council of Churches (SACC) is the facilitating body for a fellowship of 26 Christian denominations and associated Para-church organisations. Extrapolated information from Statistics SA's National Census in 2001 religious communities analysis indicates that the SACC represents some 15-16 million Christians in the country. Founded in 1968, the SACC includes among its members Protestant, Catholic, African Independent, and Pentecostal churches, representing the majority of Christians in South Africa. SACC members are committed to expressing jointly, through proclamation and programmes, the united witness of the church in South Africa, especially in matters of national debate.

2. The South African Council of Churches (SACC) thanks the Portfolio Committee on Safety and Security for the opportunity of making this submission. In the spirit of ensuring justice through its traditional prophetic witness for the poorest, marginalised and most vulnerable of the nation, a Parliamentary Office has been established and hereby we make this submission.

3. We welcome this opportunity to make a submission to government on Nuclear Energy and affirm government in its practice of promoting participatory and deliberative democracy through parliamentary hearings and other methods such as Imbizos. Furthermore, we believe that Christian churches, and the religious sector as a whole, have significant roles to play in shaping the path of moral transformation, the promotion of values such as justice, peace for humanity together with respect and care of all forms of life - known and unknown - and therefore for all creation.

4. While science and technology have the ability to further social and economic progress, they must never be allowed to exceed the pace and development of society's ability to reason and judge their moral and ethical implications for the human and earth communities. To this end an ad hoc group has utilized an exercise in deliberative democracy to reflect on the use of nuclear energy as part of a complex system of thought. We engaged in the broadest expression of thought, interest - allowing difference of opinion while working toward consensus on issues related to the use of nuclear energy.

Sustainable development

5. What is sustainable development? In short, taking the lead from various ecumenical sources, sustainable development concerns the provision for human basic need and reliance on water, energy and food as a priority over the neo-liberal and multi-national priority of gain and profit over the production and provision of these needs. In brief, sustainable development is about the "re-imaging" of global and local economic systems, their capacity for production as well as the reasons for such production. Such decision making needs to be participatory and creative because, as claimed in the example of the Indian State of Kerala, "non-creative participation will not be just, and unjust things are not sustainable."

6. So then, an approach to sustainable development warn us against the danger of economic policies that promote the principles of "bigger is better" or of economic systems based on exponential growth resulting from capital intensive business. Globally - and to large extent in South Africa as well - similar capital intensive economy has resulted in disciplined fiscal growth but has been accompanied equally by a hemorrhaging of jobs and joblessness on the other. This is a dangerous symbiosis if - as we believe is the case in the Pebble Bed Modular Reactor
- science is funded by government as business. As an exercise in the promotion of sustainable development, we therefore urge government to invest in research that explores alternative energy sources and usages more extensively. This would mean exploring more fully a "zone of complexity" that relates to " traditional energy sources and their alternatives - fossil fuels and nuclear as well as renewable sources - in order to come to broader consensus in complexity.

7. While war and conflict may open up certain areas of marketability for energy resources - witness the wars in Iraq, Afghanistan and ongoing conflict in the Middle East - such options never sustain development but rather fuel a spiral of conflict demanding an ever spiraling increase in demand for human, financial and natural capital. We caution that future joblessness is a greater challenge to human security than the protection of economic and state systems of security. What, however, if such joblessness continues and safety and security becomes plotted through jobs that rely on a path to weapons production? And what if such weapon production becomes reliance on access to enriched Uranium and Plutonium stocks whose availability and access become defined by an energy industry that makes proliferation to such material easier? War and terrorism, we argue, become political and economic ends that begin a downswing to a cycle of sustainable dest5uction rather than development.

8. The SACC has never been alarmist - and neither are we here - but argue that the level of possible nuclear harm can in no way be compared to an overdose of permissible and regulated harms caused by, say, smoking cigarettes and/or consuming alcohol. While we understand that there exist elements of harm in every source of energy we question whether
- in comparative situations such as Long Mile Island and Chernobyl disasters - regulation would provide sufficient and adequate protection for such disasters should the occur South Africa. We have then now not even begun to question dealing with such problems as Uranium depletion, Plutonium storage and destruction or even of radiation.

9.We note that
South Africa has a number of international duties to protect the environment such as, amongst others'


·         The African Peer Review Mechanism.


·         The United Nations Millennium Development Goals.


·         The World Summit on Sustainable Development Plan of Action.


·         The Rio Declaration.


·         The African Charter on Human and People's Rights.


10. At the same time, we note that there is consensus by the United Nations and scientific communities worldwide that global warning is a threat to environmental and human security.

11. Without deeper analysis of these implications at this stage, suffice it to say that these times constitute for the Churches in South Africa - if not on a global level -a Kairos - or crisis or turning point - at which we need to take stock and make decisions on global, continental, regional, national, provincial, city, local and-personal levels to live in a sustainable way. The original Kairos document in the mid eighties challenged then churches' way of reasoning' on social and political issues. This was referred to as "Church theology". It challenged what way in which the churches supported the status quo of economic and political trends of the day and called it "State theology". But it proposed a way forward with and for those who bore the brunt of apartheid - the poor, marginalized, vulnerable, especially women and children.

So, in these times of energy crisis, a Kairos would provide for a way forward through the melee of status quo energy provisions and their complementary sources as well as for alternatives. In order to do this, we recommend that extended public space be provided for questioning, deliberations, decision making on policy processes and prescriptions on our use of non­renewable resources and fossil fuels, the production of waste, population development, economic growth - especially as they relate to jobs and inequality -amongst other environmental, human security and energy related issues. We commend government for this process of deliberations and suggest that it is necessary to plot a path toward a common understanding and progression for sustainable development and livelihoods. Such a Kairos or turning point must include extended democratic decision making so as to ensure that the quality of life envisaged by our Constitution - as a base line - becomes consensus driven as well as an agreed path for present and future generations.

12. We therefore call on the government - in all transparency and through the provision of access to all relevant information
- to partner civil society and the churches in the promotion of awareness and education on issues of sustainable development and livelihoods in order to deal with the threat of global warming. Furthermore, we urge government to facilitate deliberations towards reaching consensus on the way forward through parliamentary and extra-parliamentary hearings.

Nuclear energy

13. There are others who are more qualified to make contributions on the "science and technological" implications of Nuclear energy in
South Africa. We make the following submissions of principle and process in the hope that we will assist the Portfolio Committee to search for consensus on charting a progressive course ­not necessarily or essentially toward nuclear energy as a logical progression - but rather toward a sustainable future for a range and mix of energy sources. We encourage government to deal with this matter as one of considerable complexity. We therefore make reference, in no particular order, to a diversity of socio-economic, waste management, human resource development as well as human-security related principles as they may apply to the supply and use of nuclear energy in South Africa.

13.1 Energy policy decisions should contribute to sustainable development

A legal prescription for "sustainable development" may be found in the National Environmental Management Act 107 of 1998 (NEMA) which lies at the heart ofNEMA2. Our points 5-10 above on sustainable development provide a forum, we believe, for an additional interrogation on the sustainability of energy sources. Essentially, government is required to evaluate the social, economic and environmental impacts of activity - in this case the use of nuclear energy - as it may affect the environment. The public needs to be actively involved in any decision government may take to proceed with energy development that affects the social, economic or environment of its communities.

13.2 Energy policy decisions should be based on a full accounting of current economic costs as well contributions to global warming

The People's Budget Campaign has estimated earlier this year that government has already spent R 3,85 billion likely to balloon to over R 14,84 billion for the reference module and
if the full decommissioning of the PBMR is included - on may be as high as R 25 billion by 2012. The problem of finance allocation and of priority choices is two fold. In the first instance, the PBC has no reference point as to measure the allocation for the PBMR and therefore believes it (PBMR) to be one of government's "follies"

 Secondly, the PBC has no reference to a rigorous public interrogation that underlies nuclear energy as a feasible choice. The PBC therefore suggest that the policy principle of cost-reflective pricing should be applied to the full costs of energy use be phased in while interim measures are also used. While not being prescriptive on this matter, we would refer the Portfolio Committee to the work of Herman Daly, a former economist on the Environment at the World Bank and John Cobb Jr., a professor of theology to their work "For the Common Good: Redirecting the economy towards community, the environment and a sustainable future" in which they develop a useful "Index of Sustainable Economic Welfare".

This work points further to a procedure proposed by economist Salah El Serafy (1988) in which he calculates the amount of money that would need to be set aside from the proceeds of the liquidation of a natural asset to "generate a permanent income stream that would be as great in the future as the portion of receipts from nonrenewable assets that are consumed at present.

13.3 Energy policy decisions should be transparent and take into account environmental and social impact assessments that consider threats to (a) the environment and (b) human security including threats to nuclear energy plants by war and terrorism.

13.4 Energy policy decisions should recognize and consider more equitably - when compared with considerations for nuclear energy - sustainable energy sources such as sun, wind, wave power and the use of bio-fuels as advantageous in developing a sustainable future.

In addition to 13.2 above, we note that
South Africa is blessed with an abundance of renewable sources of energy, in particular solar and wind. We believe that renewable energy is a neglected aspect of our energy mix. Of particular concern is the significant amount of nuclear waste produced by nuclear energy sources, especially the PBMR. In the case of Uranium 235, which has a half life of 7l3 million years, there exists no licensed high-level storage cite in the world. Since the time frame of decay is incalculable, we dare not take a hasty decision in sanctioning its implementation and further use. In terms 'of climate change, it is true that nuclear sources produce lese CO2 emissions than either coal or gas. However, not much is considered by factoring that nuclear energy produces much more CO2 emissions than either wind, solar thermal and/or tidal energy sources.

13.4 Energy policy decisions for the above sustainable energy sources should allocate at least an equivalent support for research and development as is currently expended on nuclear energy.

We have learnt that, in comparison with the billions spent and planned on nuclear energy, a mere R140 million has been set aside on research and development of the complete mix of renewable sources of energy. An equal investment in renewable energy part for part as for nuclear energy, we believe, will deliver an achievable goal of 15% of all electricity generation from renewable sources by 2020. This is not only achievable, but will significantly impact on the lives of all people and particularly of the poor and working class people who fork out significant increases on current energy sources.

13.5 Energy policy decisions should give practical consideration to local and consumer generation of energy and savings in order to maximize energy security and minimize cost of energy generation.

Local use of solar generation through solar thermal panels for example and other popular alternatives such as wind and tidal energy generators may easily be regulated to feed into the energy grid and compensate the consumer" or community of consumers for the production of energy. Since such generation occurs closer to the consumer and/or community of consumers, management, control and repair would be easier and cheaper to deal with than from a source/s tens or hundreds of kilometers away from supplementing the grid with energy, such alternatives also provide for greater energy security, energy savings and minimize the cost of energy generation.

13.6 Energy policy decisions should factor in and support the opportunities for local and consumer energy generation as possibilities for sustainable job creation.

In line with the above, the factorization of local energy production could provide for opportunities of local job creation through and alongside the provision of energy. An example of recycling waste into landfills for compost which in turn provides a source of food and/energy such as at the Sustainability Institute outside Stellenbosch is an excellent example of a mix of job creation from biogas and other alternatives that should be more creatively explored.

13.7 Energy policy should facilitate a choice of alternatives to consumers and regulate against the monopoly of ESKOM.

The current options toward nuclear energy occur because of a lack of alternatives or alternatives such as wind turbines proven to be uneconomical through monopolized research. During the energy crisis in the Western cape in November 2005 and through to 2006, it was generally known that the electricity grid had not been sufficiently upgraded over the past 13 years or more. ESKOM, however, is known to be accumulating significant profits, sufficient to pay extremely large salaries to its executive operating officers. Upgrading of the grid, an allowance of alternatives as well as a closer monitoring of measures ESKOM is able to promote toward alternative energy usage, could provide for both cheaper and more affordable energy sources. An example of one of ESKOM's questionable alternatives was the provision of "energy-saving lamps" for incandescent lamps. These lamps do not use significantly less energy than an incandescent lamp but still ensure that ESKOM makes a profit from energy supply. There are also environmental problems with these lamps in that they contain mercury vapour. A suggestion might be for ESKOM to consider the subsidy and/or free provision of solar panels to households and to count real cost savings in, say, five years.

13.8 Energy policy should amend building regulations to include the compulsory installation of solar/thermal water heaters for reduction of energy consumption costs which in turn could subsidize poorer households.

In line with 13.7 above and with creative alternative energy exploration, policies that amend building regulations to enable the use and provision of alternative energy sources for households such as water heaters and the inclusion of energy conservation measures, measurable savings would be made. Municipal and local government systems could then provide for wider reaching subsidies for poorer households.

13.9 Base policy on comprehensive and symbolic nuclear non proliferation as a signal of intent and purpose to the world. Apply the "do no harm principle" to health and environment first.

The energy crisis has implications for personal, community, national, regional and global levels. Much of the above principles have dealt with the first four levels. South Africa, as we stated earlier international obligations just as international socio obligations rights relate to South Africa being a part of the international and global family of humanity and ecosystems. The application of policy that led South Africa to dismantle its nuclear facilities - for whatever socio-economic and/or political cause - must under gird its intentions toward ongoing nuclear non-proliferation. In a world that faces this Kairos -and which is caught up in a spiral of nuclear program intentions as well as an end to dependence on oil - South Africa has the opportunity to lead the world in seeking the "do no harm first" principle and to promote energy alternatives that deliberately seek to compound human and environmental health rather than promote energy alternatives with unknown future and present risks such as nuclear energy.

13.10 Energy policy should explore application of nuclear energy as a final, desperate measure on indication that balance of all probabilities of current energy systems and alternatives have been sufficiently explored and applications indicate absolute non-viable, non-sustainable future use.

"Finally, it would appear logical that, seeking to promote the use of nuclear energy in any way as an alternative to fossil fuels and renewable energies would need far proof and study other than popular media strategies. As we have indicated before, proof that energy sources comply with the sustainable development criteria as well as with the most rigorous social, economic and environment impact assessments would require the most extensive democratic and participatory decision making mechanisms if it is to justify its inclusion in a mix of alternative energy sources. And then, it should not receive and/or be given priority funding over other sources that it IS currently receiving.


We thank the Department of Environment and Tourism for this opportunity to have made submission on nuclear energy. We are grateful for the democratic initiative extended to public participation for this submission. We would urge and recommend far more extensive and deliberative democratic decision making processes in order to reach the nation's common mind on nuclear usage. Due to the serious nature of climate change before the world, all face energy usage as a crisis - or theological Kairos - that needs to be weighed against the most stringent criteria for sustainable development possible. Against this backdrop the Churches have proposed a selection of criteria and/or principles for energy use. Chief amongst these must be the need to evaluate current energy sources together with nuclear and renewable in the most objective fashion possible in order to find a combination that cares for the environment while also generating sustainable livelihoods for our present generation and for generations to come.


Mr. Eddie Makue. General Secretary, SA Council of Churches