Comments on Draft National Coastal Management Programme
On 28 March 2025, under the National Environmental Management: Integrated Coastal Management Act (NEM:ICMA), the Minister of Forestry, Fisheries and the Environment published South Africa’s revised draft National Coastal Management Programme for 2025-2030 (Draft NCMP) for public comment. NEM:ICMA regulates management of the coastal zone. As the Draft NCMP itself states, an NCMP is NEM:ICMA’s “principal implementation tool”, that “serves as both compass and catalyst for coastal governance in South Africa”, because it informs the policies and actions of national, provincial and local government. The Draft NCMP is preceded by a 2015 – 2019 NCMP.
However, we found that the Draft NCMP undermines both its statutory function and the vision of its previous iteration, as it is an unworkably vague document that fails to do what NEM:ICMA requires, what the 2015 – 2019 NCMP set it up to do, or even what the Draft NCMP itself says it does. We therefore submitted detailed comments towards it fulfilling its function. In brief, the BLC’s comments critiques six aspects of the Draft NCMP.
First, we found that the Draft NCMP’s misses the constitutional environmental rights’ emphasis on ecologically sustainable development, which misinterpretation permeates throughout the Draft NCMP, such that it does not foreground the protection of biodiversity, on which all life and livelihoods depends.
Second, contrary to NEM:ICMA’s requirements, the Draft NCMP does not include any norms and standards for the management of the coastal zone and its specific components, nor does it clarify whether these norms and standards already exist. Our view is that this also flouts NEM:ICMA’s requirement that the Minister sufficiently informs the public on the protection and management of the coastal zone so that we can make informed decisions on the extent to which the State is fulfilling its duties under the constitutional environmental rights and NEM:ICMA.
Third, the Draft NCMP narrowly interprets international obligations, focusing only on KMGBF Target 3 and reducing it to ocean conservation. This ignores coastal ecosystems and other relevant targets, overlooking broader biodiversity commitments. It also omits binding agreements like UNCLOS and MARPOL, missing opportunities to align coastal management with international law.
Fourth, the Draft NCMP includes a 2025-2030 Implementation Plan that is vague and fails to provide for a priority specifically concerned with biodiversity conservation, as well as failing to provide for the involvement of non-governmental organisations, the private sector and local communities in coastal management as required by NEM:ICMA. The Implementation Plan also fails to provide for how its actions will be funded, and is vague in terms of climate change impacts and objectives.
Fifth, almost 16 years after NEM:ICMA’s commencement, the Draft NCMP provides for unclear State of the Coasts (SOC) Reporting. NEM:ICMA requires the Minister to regularly report on the SOC. The Draft NCMP refers to the importance of this reporting, but is not clear on whether any SOC reporting has ever been done, and we have been unable to find any such reports. While the Draft NCMP provides for potential SOC Reporting indicators, we found these to fall short of NEM:ICMA’s requirements, and to be confusingly vague and needlessly narrow.
Sixth, despite the Draft NCMP’s recognition that limited resources impede coastal provinces and municipalities’ implementation of NEM:ICMA and their coastal management capacity, the Draft NCMP refers to unexplained priorities with which provinces must align and requires municipalities to fulfil additional implementation requirements without meaningfully providing for corresponding resources to do so.
As it stands, the Draft NCMP’s purported “recogni[tion] of the coast’s multifaceted role as an economic corridor, cultural treasure, and ecological lifeline” is superficial, as are its references to “lessons learned” from the 2015 – 2019 NCMP, and to the realities of marginalised communities and widespread capacity challenges. It is therefore inadequate to serve as NEM:ICMA’s “principal implementation tool”, or to inform other NEM:ICMA programmes or committees.
Our full comments are included below: