{"query_echo":{"q":"","filters":{"climate_tags":["environmental impact assessment (eia)"]},"warnings":[{"code":"facet_value_not_in_vocabulary","message":"Value 'environmental impact assessment (eia)' for facet 'climate_tags' is not in the controlled vocabulary."}]},"total":{"value":2,"relation":"eq"},"page":1,"page_size":20,"self":"https://climateinsightsdirectory.org/api/v1/search?climate_tags=environmental+impact+assessment+%28eia%29","stability":"beta","ai_marking":{"digital_source_type":{"uri":"http://cv.iptc.org/newscodes/digitalsourcetype/trainedAlgorithmicMedia","name":"Created using Generative AI"},"notice":"Summary and key insights are generated using artificial intelligence."},"results":[{"id":"cer-001096","url":"https://climateinsightsdirectory.org/document/cer-001096","title":"COMMENTS ON THE INTENDED DRAFT GUIDELINE FOR CONSIDERATION OF CLIMATE CHANGE IMPLICATIONS IN APPLICATIONS FOR ENVIRONMENTAL AUTHORISATIONS, ATMOSPHERIC EMISSIONS LICENSES AND WASTE MANAGEMENT LICENCES","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":"2021-07-23","source_url":"https://cer.org.za/wp-content/uploads/2021/07/LAC-Submission-National-Guideline-for-Climate-Change-Considerations_26-July-2021.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"The Centre for Environmental Rights (CER), representing groundWork and Earthlife Africa, submitted comments on July 23, 2021, regarding the Department of Forestry, Fisheries and the Environment's (DFFE) draft Guideline for considering climate change implications in environmental authorisations and licenses. While welcoming the initiative, the CER argues that the draft is insufficient to address the climate crisis and fails to meet the legal requirements of the Constitution and the National Environment Management Act (NEMA). The submission advocates for a 1.5°C warming limit as the primary benchmark for emissions assessments rather than Nationally Determined Contributions (NDCs), and calls for the inclusion of social costs of carbon and full lifecycle GHG emissions in project evaluations.","ai_generated":true,"unit":"cer-001096#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The CER contends that South Africa's Nationally Determined Contributions (NDCs) are an inadequate benchmark for assessing an activity's climate change mitigation impacts because they are based on executive discretion and may not align with a safe emission reduction pathway. The CER argues that the benchmark should instead be a 1.5°C warming limit, noting that the draft NDC update from March 30, 2021, is 'insufficient' and the 2015 NDC is 'highly insufficient' according to Climate Action Tracker.","ai_generated":true,"unit":"cer-001096#insight-1","date_modified":"2026-08-17"},{"text":"The submission urges the DFFE to require an assessment of the external and social costs of carbon emissions for proposed projects. The CER suggests using the USA's social cost of carbon (SCC) protocol or an equivalent methodology to quantify damages—such as impacts on GDP, biodiversity, and human health—that are typically not paid for by project proponents, aligning with the NEMA principle that costs of remedying pollution must be paid by those responsible.","ai_generated":true,"unit":"cer-001096#insight-2","date_modified":"2026-08-17"},{"text":"The CER argues that climate impact assessments must adopt a full lifecycle and cumulative approach rather than assessing activities in isolation. This includes examining the full footprint of a project, its effects on carbon sinks, and how a single proposal contributes to the cumulative effects of other past, current, and future projects.","ai_generated":true,"unit":"cer-001096#insight-3","date_modified":"2026-08-17"},{"text":"The CER emphasizes the need to integrate equity and socio-economic considerations into climate assessments, specifically focusing on vulnerable groups such as women, children, the elderly, and poor communities who disproportionately bear the brunt of climate impacts. They recommend that the Guideline explicitly require the identification of disproportionate impacts on these groups to enable proactive public participation.","ai_generated":true,"unit":"cer-001096#insight-4","date_modified":"2026-08-17"},{"text":"The submission recommends expanding the definition and assessment of 'stranded assets' to include risks related to the economics of renewable energy, stricter GHG emission limits, regulatory risks, and market changes. The CER notes that the impacts of stranded assets extend beyond owners to include costs to public funds and society through job losses and decommissioning.","ai_generated":true,"unit":"cer-001096#insight-5","date_modified":"2026-08-17"},{"text":"The CER suggests that the climate impact guidance should be extended beyond the DFFE's mandate to include other licensing processes, such as water use licensing, electricity generation licenses by the National Energy Regulator, and scheduled trade permitting by local governments, to ensure consistency across government decision-making.","ai_generated":true,"unit":"cer-001096#insight-6","date_modified":"2026-08-17"}],"climate_tags":["ghg emissions","nationally determined contributions (ndcs)","1.5°c warming limit","social cost of carbon","environmental impact assessment (eia)","stranded assets","climate justice","lifecycle assessment"],"geography_discussed":["Southern Africa"],"frame_perspective":[],"analysis_type":["policy_commentary","legal_submission"]},{"id":"cer-000993","url":"https://climateinsightsdirectory.org/document/cer-000993","title":"GROUNDWORK’S RESPONDING STATEMENT TO KARPOWERSHIP SA (PTY) LTD’S APPEAL AGAINST THE ENVIRONMENTAL AUTHORISATION REFUSAL DECISION (EA NO. 14/12/16/3/3/2/2007): RICHARDS BAY","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":null,"source_url":"https://cer.org.za/wp-content/uploads/2021/08/groundWork-Responding-statement-on-Karpowership-Richards-Bay-EA-Appeal....pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","analysis_type"],"summary":{"text":"This responding statement, submitted by groundWork to the Department of Forestry, Fisheries and the Environment (DFFE), argues for the dismissal of Karpowership SA (PTY) Ltd’s appeal against the refusal of an Environmental Authorisation (EA) for a gas-to-power project in Richards Bay. groundWork contends that the project is neither necessary nor desirable, citing significant environmental risks, inadequate public participation, and the existence of more cost-effective, renewable energy alternatives.","ai_generated":true,"unit":"cer-000993#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The proposed Karpowership project in Richards Bay would consist of two powerships and a Floating Storage Regasification Unit (FSRU) with a 540MW capacity, a 3km transmission line with 13 towers, and a subsea gas pipeline. The project is expected to release approximately 17 million tCO2e over 20 years, with additional direct and indirect emissions, totaling roughly 0.82% of South Africa's national carbon budget.","ai_generated":true,"unit":"cer-000993#insight-1","date_modified":"2026-08-17"},{"text":"The project site is located in an ecologically sensitive area featuring irreplaceable Critical Biodiversity Areas (CBA), endangered mangroves, and rare estuarine systems. Specifically, the Richards Bay and uMhlathuze estuaries support 47% (652.1 ha) of South Africa's mangrove habitat, and the area is a preferred habitat for the Ocean Humpback Dolphin.","ai_generated":true,"unit":"cer-000993#insight-2","date_modified":"2026-08-17"},{"text":"groundWork disputes the 'need and desirability' of the project, citing studies from CSIR and Meridian Economics which suggest that South Africa does not need to expand gas infrastructure for the foreseeable future. These reports indicate that a least-cost scenario involves rapidly building out wind and solar generation, and that new gas capacity is not required to prevent load-shedding for at least the next decade.","ai_generated":true,"unit":"cer-000993#insight-3","date_modified":"2026-08-17"},{"text":"The DFFE refused the Environmental Authorisation based on several material gaps, including the failure to conduct a qualitative Underwater Noise Impact Assessment for megafauna (such as the Humpback Dolphin) and the failure to consider the effects of heated water discharge into the marine environment.","ai_generated":true,"unit":"cer-000993#insight-4","date_modified":"2026-08-17"},{"text":"The public participation process is alleged to have been legally insufficient. groundWork claims that the draft environmental impact assessment (DEIR) was not subject to the required 30-day public participation, documents were password-protected or removed from the website, and extensive changes made to the Final Environmental Impact Report (FEIR) were not subjected to further consultation as required by Regulation 23(1)(b) of the EIA Regulations.","ai_generated":true,"unit":"cer-000993#insight-5","date_modified":"2026-08-17"},{"text":"The project's socio-economic assessment is criticized for being defective. It allegedly ignores the economic value of 'blue carbon' services provided by mangroves and seagrass, the impact of noise on fisheries and tourism, and the long-term financial risk of locking the country into an expensive 20-year power purchase agreement for gas.","ai_generated":true,"unit":"cer-000993#insight-6","date_modified":"2026-08-17"},{"text":"Expert analysis by Michelle Fournet indicates that the EIA failed to quantify baseline ambient sound levels and failed to model sound propagation specifically for the Richards Bay site, relying instead on inapplicable data from Ghana. This lack of site-specific modelling prevents an accurate assessment of impacts on marine mammals and prey species.","ai_generated":true,"unit":"cer-000993#insight-7","date_modified":"2026-08-17"},{"text":"The document asserts that expanding natural gas infrastructure is incompatible with the global goal of limiting warming to 1.5°C, as outlined in the UNEP Global Methane Assessment. It argues that the project's high methane and CO2 emissions would be counterproductive to South Africa's climate commitments and the Paris Agreement.","ai_generated":true,"unit":"cer-000993#insight-8","date_modified":"2026-08-17"}],"climate_tags":["energy transition","gas-to-power","blue carbon","methane emissions","climate mitigation","environmental impact assessment (eia)"],"geography_discussed":[],"frame_perspective":[],"analysis_type":["Policy Response","Legal Submission","Environmental Impact Critique"]}]}