Eskom’s visual specialist assessed the proposed facility and rated its impact HIGH — with no effective mitigation possible. Reactor buildings, cooling towers and transmission infrastructure of this scale cannot be screened or concealed. The finding is in the official DSR. St Francis Bay’s economy, property values and tourism market all depend on this coastline’s character. That character would change permanently.

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VISUAL IMPACT — APPENDIX G15

“The visual impact of the proposed development is rated HIGH. No effective mitigations exist for a nuclear power facility of this scale in a coastal landscape.”

Eskom’s own visual specialist, DSR 2026

6.4 million cubic metres of excavation. 4.5 million cubic metres dumped in the ocean. Eskom’s 2026 report uses the word ‘irreversible’ to describe the potential long-term impact on surf breaks. At Bantamsklip — the alternative site — the same report rates the surf break impact Very Low with High confidence. Thyspunt: Medium with only Moderate confidence. The site comparison table omits this differential entirely.  

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SURF BREAKS — APPENDIX G13

“Disposal of large quantities of material may have an irreversible impact on surf breaks in the long-term.”

Eskom’s marine specialist, DSR 2026

The chokka squid fishery is one of South Africa’s most significant inshore fisheries. The cooling system draws 76,000 litres per second per reactor unit through critical spawning habitat. Eskom’s marine report rates the impact Very High before mitigation — and has not modelled this at the full 5,200 MW scale. No independent peer review has been conducted for the Thyspunt-specific marine studies.  

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MARINE ECOLOGY — APPENDIX G12

“Impacts of particular concern are identified. The marine assessment does not reflect the full 5,200 MW operational scale.”

Eskom’s marine ecology specialist, DSR 2026

January 2025: SAHRA declared the Thyspunt site a Grade I Cultural Landscape — equivalent to Robben Island. The coastline contains 160,000 years of archaeological history. The DSR does not address what this means for the project, does not clarify the Section 28 permit requirement, and does not explain how a nuclear facility is compatible with Grade I protection.  

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HERITAGE — SAHRA GAZETTE NO. 52013

“The provisional Grade I Cultural Landscape declaration covers the Thyspunt development footprint. Lapses 1 February 2027.”

SAHRA, January 2025

The Oyster Bay dunefield moves 10 to 30 metres per year. Eskom’s own geomorphologists call it unique on a local, regional and probably global scale. A nuclear power station requires fixed infrastructure for 60+ years. The EIA has not established that permanent nuclear infrastructure can coexist with a system that has been migrating continuously for thousands of years. The dunefield sits above a sensitive, interconnected double-aquifer groundwater system. Two boreholes across 250 hectares is not adequate baseline data.  

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DUNE GEOMORPHOLOGY — APPENDIX G01

“The headland-bypass dunefields at Cape St Francis are unique on a local, regional and probably global scale. Dunes move at 10 to 30 metres per year.”

Eskom’s dune geomorphology specialist, DSR 2026

The ministerial determination authorising nuclear procurement was withdrawn in August 2024 after a legal challenge found the public participation process deficient. No valid replacement has been confirmed. Without a Section 34 determination, neither the 5,200 MW quantum nor Eskom’s role as procurer has confirmed statutory foundation. The Kromme Enviro-Trust has formally requested confirmation of the legal basis on which this EIA is proceeding.  

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Legal reference: Section 34(1) Electricity Regulation Act · Earthlife Africa v Minister of Energy (2017) · Kromme Enviro-Trust primary submission, 30 April 2026