Ramrod Politics

Draft Oceans Economy Master Plan (No. 5) 

Today’s online consultation bordered on the absurd. Despite overwhelming criticism from commercial fisheries, maritime stakeholders, small-scale fishers and Indigenous coastal community leaders, the fifth draft of the OEMP continued to prioritise the expansion of offshore oil and gas “through increased investment into and removal of barriers to the sector (DMRE, 2025).“

Even more strikingly, the document [see below] explicitly stated that climate equity, intergenerational justice and the precautionary principle—all central principles of contemporary environmental governance—”are not discussed in any detail.” Rather than demonstrating robust strategic planning, the document appeared to acknowledge the omission of the very considerations that ought to underpin marine spatial governance.

Herewith ONO’s response to the Draft No. 5 Oceans Economy Master Plan (OEMP), confined to Section 9, the Offshore Oil and Gas Sub-Sector Plan, Please make your public comments to the department here:

1. Summary of concerns
   1. Section 9 consistently frames legitimate civil society opposition, community objection and litigation as sources of ‘regulatory complexity’ or investment risk, rather than as lawful exercises of public participation rights under the Constitution and the National Environmental Management Act (NEMA). This framing pre-judges the legitimacy of that opposition before the Master Plan has been finalised.
      
   2. The Plan repeatedly deploys ‘Just Energy Transition’ and related climate-policy language (JET-IP, net zero, decarbonisation) to characterise continued and expanded offshore oil and gas licensing, without demonstrating how expanded extraction is compatible with South Africa’s Nationally Determined Contribution (NDC), the Climate Change Act 2024, or the 1.5°C goal of the Paris Agreement.
      
   3. The Plan does not engage with the precautionary principle (NEMA s.2(4)(a)(vii)) as a substantive constraint on offshore licensing decisions, notwithstanding its own acknowledgment of an unresolved regulatory gap on climate change impact assessment in the EIA process.
      
   4. The Plan’s treatment of coastal and fishing communities and Indigenous groups is limited to their appearance as a source of legal and reputational risk. There is no engagement with free, prior and informed consultation, customary and constitutional rights, or the socio-economic and cultural stakes of coastal communities in marine ecosystems.
      
   5. The Plan’s 24-year target horizon (through 2045-2050) rests on an implicit assumption of gradual, near-linear climate change. Recent peer-reviewed research on Atlantic Ocean circulation weakening, accelerating ice-sheet melt and diverging South African rainfall projections increasingly calls that assumption into question, with material implications for the Plan’s own infrastructure and production targets.
      
   6. The comparator case studies (Guyana, Namibia, Mozambique) are presented as models of successful transformation without reference to the resource-curse literature, the distribution of benefit within those economies, or the ecological and climate costs of the developments cited. Mozambique’s Rovuma Basin LNG development in particular is cited as a source of regional ‘lessons’ without any acknowledgment of the conflict, displacement and security costs associated with it.
      
   7. The Plan omits any account of the scale, duration or outcome of the public participation process that has already occurred in relation to offshore oil and gas — including the 2021–2025 comment and litigation record — despite citing its procedural consequences (e.g., the August 2025 Block 5/6/7 ruling) as a cost to be managed.
      
   8. Marine ecology, biodiversity and the cumulative environmental effects of seismic survey, drilling and potential spill events are addressed only incidentally, subordinate throughout to resource, revenue and investment framing.
      

2. Detailed comment

2.1 The framing of opposition, consultation and litigation as regulatory risk (§9.2, §9.4)

Section 9.2 lists, as one of three categories of challenge facing the sub-sector, ‘opposition to oil and gas mainly by environmental activists/non-governmental organizations, coastal fishing communities, and indigenous communities’ alongside ‘climate change activism’ and permitting bottlenecks. Section 9.4 repeats this pattern, listing litigation risk and stakeholder consultation as constraints on investor confidence to be resolved through streamlined consultation templates (§9.10, Focus Area: Expand exploration and appraisal).

This is a consequential framing choice, not a neutral description. It places the exercise of constitutional and statutory participation rights — the right to lodge appeals, seek judicial review, and object to environmental authorisations under NEMA — in the same analytic category as bureaucratic delay and market volatility. It treats the outcome of that participation (for example, the setting aside of authorisations for Block 5/6/7 in August 2025) as a cost imposed on the sector, without acknowledging the underlying finding that produced it: that the authorisation process itself was legally deficient.

Question 1: Does the Master Plan’s characterisation of public objection and litigation as ‘regulatory and legal complexity’ (§9.2(iii)) and as a constraint on ‘investor confidence’ (§9.4) reflect the drafters’ considered position that these are properly understood as costs to the sub-sector, rather than as constitutionally protected public participation? If not, will this framing be revised?

Question 2: What account does the Plan give of the substance of the objections raised in the litigation it references (including the Block 5/6/7 authorisations and other stalled exploration initiatives cited in §9.2), rather than only their procedural effect on project timelines?

Question 3: Section 9.10 proposes to ‘strengthen and streamline stakeholder and community consultation processes through standard consultation guidelines and templates’. What safeguards will ensure that standardisation is not used to narrow the scope, duration or substantive weight given to community and civil society input relative to current NEMA processes?

2.2 The use of ‘Just Energy Transition’ language to characterise continued extraction (§9.8–§9.10)

Section 9.8 correctly cites the ILO’s definition of a just transition as a whole-of-economy approach that reduces the impact of job losses and industry phase-out on workers and communities while producing new, green and decent jobs. It then applies the language of the Just Energy Transition — JET-IP, net zero by 2050, decarbonisation — to a sub-sector plan whose substantive targets (§9.10) are the expansion of exploration and appraisal activity, competitive licensing rounds, and production through to 2045.

Natural gas is described as a ‘significant transitional fuel’ on the basis of its lower emissions intensity relative to coal (§9.8), but the Plan does not model whether continued and expanded offshore oil and gas licensing is consistent with South Africa’s second NDC, the Climate Change Act’s forthcoming Sectoral Emissions Targets, or the 1.5°C carbon budget. The Plan itself notes (§9.9) that the draft Sectoral Emissions Target does not yet contain an emissions reduction target for the petroleum sector, and that a national guideline on incorporating climate change into environmental authorisations, published for comment in October 2025, does not resolve this regulatory gap.

Read together, these sections use the vocabulary of a just and orderly transition to describe a plan whose measurable content is expansion. ONO’s concern is that this is not only an imprecision of language: it risks pre-empting and neutralising the substantive meaning of ‘just transition’ as it is used in South Africa’s own climate policy architecture and in civil society’s own submissions on that architecture.

Question 4: Has the Master Plan modelled the full lifecycle (Scope 1–3) greenhouse gas implications of the offshore oil and gas targets set out in §9.10 against South Africa’s second NDC commitments and the 2025-peak, post-2026-decline emissions trajectory described in §9.8? If so, will that modelling be published alongside the next draft?

Question 5: Given the Plan’s own acknowledgment that the Sectoral Emissions Target for the petroleum sector is not yet developed (§9.9), on what basis does the Plan proceed to set 2045 production and exploration targets (§9.10) in advance of that sectoral carbon budget being finalised?

Question 6: Will the Master Plan adopt a definition of ‘just transition’ for the offshore oil and gas sub-sector that is consistent with the ILO definition it cites in §9.8 — including measurable commitments on job transition, community benefit and phase-out planning — rather than using the term to describe continued licensing activity?

2.3 Absence of the precautionary principle and of community consent

NEMA’s principles, which the Plan’s own regulatory review (§9.9) identifies as governing offshore environmental authorisation, include the precautionary principle: that a risk-averse and cautious approach should be applied where there is uncertainty regarding the environmental consequences of an activity. Section 9 does not engage with the precautionary principle as a substantive standard against which offshore licensing decisions should be tested. Nor does the Plan engage with the concept of free, prior and informed consultation with affected coastal and Indigenous communities, notwithstanding that such communities are named repeatedly in the Plan as parties to be managed through consultation.

Question 7: How does the Master Plan propose to give effect to the precautionary principle in setting offshore exploration and appraisal targets (§9.10), given the acknowledged regulatory gap on climate change impact assessment (§9.9) and the absence of a finalised sectoral carbon budget?

Question 8: What standard of consultation does the Plan intend for coastal fishing communities and Indigenous communities specifically — free, prior and informed consultation, or the general public participation standard applicable to all interested and affected parties under NEMA? If the latter, how does the Plan reconcile this with these communities’ distinct customary, cultural and livelihood relationships to the marine environment?

2.4 Ecological omissions: the marine environment as resource rather than as stakeholder

Throughout Section 9, the ocean is referenced almost exclusively in resource terms — basins, reserves, acreage, prospective resources — and marine science is valued in §9.7 principally for its capacity to reduce exploration risk and support basin modelling. Cumulative ecological effects of seismic survey activity, well drilling and the risk of a blowout or spill event are addressed only incidentally (for example, the reference to the Interim Incident Management Organisation in §9.10’s targets table) rather than assessed as a standing constraint on the scale and pace of licensing set out in the Plan.

Question 9: Does the Master Plan intend to commission or publish a cumulative environmental impact assessment for offshore oil and gas activity across all basins identified in §9.2 and §9.10, independent of project-by-project EIAs, prior to setting sector-wide 2045 production targets?

Question 10: What assessment has been made of blowout and spill risk associated with the ultra-deepwater exploration referenced in §9.1 and §9.2 (including in the Orange Basin, where water depths approach South Africa’s technological limits), and will this assessment be made publicly available?

2.5 The Guyana, Namibia and Mozambique comparators

Sections 9.1 and 9.10 present Guyana’s and Namibia’s offshore discoveries as models for South Africa to emulate, citing GDP growth, state revenue and production volumes. The Plan does not engage with the distribution of benefit within those economies, the environmental and climate costs of the developments cited, or the extensive international literature on the risks of resource-dependent growth (the ‘resource curse’). Nor does it address whether the institutional, fiscal and regulatory conditions that produced those outcomes are present, or achievable, in South Africa.

Section 9.2 also cites Mozambique’s Rovuma Basin gas reserves and LNG development as a regional precedent offering ‘lessons in infrastructure, financing, and regulatory alignment’, and Section 9.1 lists Mozambique alongside Angola in its overview of frontier reserves. This comparator is presented without any reference to the trajectory of the Rovuma project itself, which is directly instructive as a resource-curse case rather than a straightforward success story. TotalEnergies declared force majeure on the Mozambique LNG project in April 2021 after an insurgency in Cabo Delgado — the province hosting the project — escalated into an attack on the nearby town of Palma, part of a conflict that has since killed thousands and displaced more than a million people. The project resumed construction only in January 2026, after almost five years, and remained dependent on the continued deployment of foreign troops (including Rwandan forces) to secure the site. Independent reporting has also noted that more than 80% of Mozambicans lived below the World Bank’s $3-a-day poverty line as of 2022, notwithstanding the scale of the gas reserves the country holds, and that environmental and human rights groups have raised sustained concerns about resettlement, compensation and the distribution of project benefit to affected communities.

The Rovuma case demonstrates precisely the risk the resource-curse literature identifies: that offshore hydrocarbon discovery does not translate reliably into broad-based development, and can instead concentrate benefit, entrench security costs, and — where extraction proceeds in the presence of pre-existing inequality, marginalisation or grievance — contribute to the conditions for conflict. ONO’s concern is that the Plan cites Mozambique’s reserve size and ‘regulatory alignment’ lessons while omitting the single most material lesson the case offers South Africa: that the presence of large reserves is not, by itself, evidence of a viable development model.

Question 11: On what basis does the Plan treat Guyana’s, Namibia’s and Mozambique’s offshore revenue outcomes as reliable projections for South Africa, and has an equivalent risk assessment been conducted of the potential for uneven distribution of benefit, fiscal volatility, or stranded-asset exposure as global demand patterns shift?

Question 12: Given that the Mozambique comparator cited in §9.2 is drawn from a project that suffered a near five-year suspension linked to conflict, displacement and security costs in Cabo Delgado, will the Plan revise its treatment of this comparator to address the resource-curse and social-licence risks it demonstrates, rather than citing it solely as a source of infrastructure and regulatory lessons?

2.6 The Plan’s 24-year horizon and accelerating physical climate risk

Section 9.10 sets production and exploration targets running through to 2045, a 24-year planning horizon from the Master Plan’s current drafting date. Section 9.8 references the Just Energy Transition pathway to 2050 but does not test the sub-sector’s own targets against the physical climate trajectory that horizon actually implies. Recent research gives specific reasons to question whether the smooth, near-linear climate trajectory implicit in the Plan’s 2045 targets remains a sound planning assumption.

On ocean circulation: peer-reviewed studies published in 2026 (including work by Nian, Willeit, Wunderling, Ganopolski and Rockstrom in Communications Earth & Environment, and by Portmann and colleagues in Science Advances) report that the Atlantic Meridional Overturning Circulation (AMOC) is weakening faster than earlier climate model generations projected. Independent tipping-time analysis places a median AMOC collapse estimate around mid-century, with a 10-90% range spanning roughly 2037 to 2064 — squarely inside the Plan’s own 2021-2045 horizon — and leading researchers now place the probability of collapse before 2100 above 50%. The same body of research indicates that, once triggered, AMOC collapse would likely be irreversible on human timescales at current atmospheric CO2 concentrations. AMOC weakening is associated in the literature with a southward shift of the tropical rain belt and disruption to established precipitation regimes across the Atlantic basin and adjoining landmasses — effects whose full regional implications for southern Africa are still being established, but which represent a material source of structural uncertainty that the Plan’s horizon does not address.

On the cryosphere and sea level: 2026 studies documenting record extreme melt events across the Greenland ice sheet, and accelerated melting of Antarctic ice shelves from below, indicate that ice-sheet mass loss and its associated feedback mechanisms (meltwater lakes accelerating glacier flow; warm-water intrusion beneath ice shelves) are proceeding faster than prior model generations assumed. This bears directly on the pace of sea-level rise relevant to the siting, design life and spill-contingency planning of the offshore and coastal infrastructure this Plan proposes to expand.

On South African rainfall specifically: a 2026 study of South African extreme rainfall using CMIP6 ISIMIP models projects intensifying and diverging regional patterns through the century — increasing dry extremes concentrated in the southwestern Cape alongside increasing wet extremes and flood risk concentrated in the eastern interior and KwaZulu-Natal. This divergence bears directly on water availability for the onshore gas processing and GTL operations referenced in §9.2, on the resilience of coastal infrastructure named throughout the Plan, and on the energy security framing in §9.8, which treats current supply and demand geography as a stable planning basis through 2045.

ONO’s concern is that the Plan’s targets are set against an implicit assumption of gradual, linear climate change consistent with older central-estimate pathways, at a moment when the peer-reviewed literature is moving toward higher-probability, faster and more abrupt physical outcomes within the Plan’s own planning window. A precautionary approach, consistent with the NEMA principle already discussed in section 3.3 above, would test the Plan’s targets against these more recent and more likely risk profiles rather than against the more conservative assumptions embedded in the baseline studies cited elsewhere in Section 9.

Question 13: What climate baseline and time horizon (which emissions pathway, which model generation) underlies the 2045 production and exploration targets in §9.10, and has this baseline been tested against the 2025-2026 peer-reviewed literature indicating faster AMOC weakening, higher collapse probability, and accelerated ice-sheet mass loss than earlier model generations projected?

Question 14: Given that current AMOC tipping-point estimates place a median collapse year within the Plan’s own 2045 horizon, will the Master Plan commission or reference a scenario analysis testing offshore infrastructure, coastal facilities and the sub-sector’s production targets against an AMOC disruption scenario, rather than treating this as a risk outside the Plan’s planning window?

Question 15: How does the Plan’s energy security framing (§9.8) and its onshore processing and pipeline infrastructure planning (§9.2) account for the divergent regional rainfall trajectory that recent South African-specific climate modelling projects — including intensifying drought risk in the southwestern Cape and increasing flood risk in the eastern interior and KwaZulu-Natal — over the same 2021-2045 period covered by the Plan’s targets?

3. Recommendations

1. Revise Section 9.2 and 9.4 to describe public participation, community objection and litigation in terms consistent with their constitutional and statutory status, distinct from commercial and regulatory risk factors.
   
2. Publish full lifecycle (Scope 1-3) greenhouse gas modelling for the 2045 targets set out in §9.10, tested against South Africa’s second NDC and an interim sectoral carbon budget for petroleum, before those targets are finalised.
   
3. Adopt and apply a definition of ‘just transition’ for the offshore oil and gas sub-sector consistent with the ILO definition cited in the Plan itself, including measurable job-transition and community-benefit commitments.
   
4. Commission a cumulative environmental impact assessment across all offshore basins identified in the Plan, addressing seismic, drilling and spill risk, prior to finalising sector-wide production targets.
   
5. Set out explicitly how the precautionary principle and, for coastal and Indigenous communities, free, prior and informed consultation will be applied in offshore licensing decisions under the Plan.
   
6. Test the Plan’s 2045 targets against updated, higher-risk climate trajectories — including recent findings on AMOC weakening, accelerated ice-sheet mass loss, and regionally divergent South African rainfall projections — rather than against the more conservative baseline assumptions embedded in the Plan’s current climate references.
   
7. Provide a substantive account of the international resource-curse literature and distributional risk alongside the Guyana, Namibia and Mozambique comparators used to justify the Plan’s growth projections, including explicit reference to the conflict, displacement and social-licence costs evident in Cabo Delgado.

4. Closing

ONO welcomes the opportunity to comment on the Draft No. 5 Oceans Economy Master Plan and requests that this submission, and responses to the questions raised above, be recorded as part of the public comment record for Section 9. We would welcome the opportunity to engage directly with the drafting team on these matters ahead of finalisation.