COMMENTS ON PROPOSED AMENDMENTS TO THE SECTION 24H REGISTRATION AUTHORITY REGULATIONS

The Centre for Environmental Rights (CER) submitted comments to the Department of Forestry, Fisheries and the Environment regarding proposed amendments to the Section 24H Registration Authority Regulations (EAPASA Regulations). The CER objects to further delays in the mandatory registration of environmental assessment practitioners (EAPs) and requests clarification to ensure that the amendments do not restrict the public's right to lodge internal appeals under section 43 of the National Environmental Management Act (NEMA).

• The Centre for Environmental Rights (CER) strongly objects to a proposed six-month extension for environmental assessment practitioners (EAPs) to register with the Environmental Assessment Practitioners Association of South Africa (EAPASA). The CER notes that the original regulations were published in July 2016, and with the proposed change, industry professionals would have had over six years to register.
• The CER argues that the lack of a legal duty for EAPs to register with EAPASA prevents the body from exercising oversight in an industry that requires regulation. To illustrate this need, the CER cites a 2021 recommendation by the Green Scorpions for criminal charges against an EAP for misleading the Department of Forestry, Fisheries and the Environment, and an appeal involving Buchuberg Resources where an EAP was accused of plagiarism and lacking the proper accreditation to sign off on reports.
• The CER requests that the Department clarify whether the proposed amendments to Regulation 6 and Regulation 14(1)(f) restrict the ability of interested and affected parties (I&APs) to lodge internal appeals under section 43 of NEMA. While the CER does not believe the amendment intends to restrict appeals to only registered EAPs, it warns that such a restriction would unlawfully curtail the ability to challenge environmental authorisations.

APA

Centre for Environmental Rights (2022). COMMENTS ON PROPOSED AMENDMENTS TO THE SECTION 24H REGISTRATION AUTHORITY REGULATIONS. https://cer.org.za/wp-content/uploads/2022/02/CER-Comments-on-proposed-changes-to-EAPASA-Regulations-28-January-2022.pdf?x21779

Chicago

Centre for Environmental Rights. COMMENTS ON PROPOSED AMENDMENTS TO THE SECTION 24H REGISTRATION AUTHORITY REGULATIONS. 2022. https://cer.org.za/wp-content/uploads/2022/02/CER-Comments-on-proposed-changes-to-EAPASA-Regulations-28-January-2022.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=COMMENTS ON PROPOSED AMENDMENTS TO THE SECTION 24H REGISTRATION AUTHORITY REGULATIONS |date=28 January 2022 |url=https://cer.org.za/wp-content/uploads/2022/02/CER-Comments-on-proposed-changes-to-EAPASA-Regulations-28-January-2022.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2022comments, author = {{Centre for Environmental Rights}}, title = {{COMMENTS ON PROPOSED AMENDMENTS TO THE SECTION 24H REGISTRATION AUTHORITY REGULATIONS}}, publisher = {Centre for Environmental Rights}, year = {2022}, month = jan, url = {https://cer.org.za/wp-content/uploads/2022/02/CER-Comments-on-proposed-changes-to-EAPASA-Regulations-28-January-2022.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }