REGULATIONS FOR THE USE OF WATER FOR EXPLORATION AND PRODUCTION OF ONSHORE NATURALLY OCCURRING HYDROCARBONS THAT REQUIRE STIMULATION, INCLUDING HYDRAULIC FRACTURING AND UNDERGROUND COAL GASIFICATION, TO EXTRACT, AND ANY ACTIVITY INCIDENTAL THERETO THAT MAY IMPACT DETRIMENTALLY ON THE WATER RESOURCE
Summary
The Centre for Environmental Rights (CER) argues that the proposed 2024 regulations for unconventional hydrocarbon extraction in South Africa are insufficient to protect water resources and the climate. The CER highlights the extreme water intensity of fracking, the risk of groundwater contamination from toxic chemicals and radioactive materials, and the lack of state capacity for compliance monitoring. They specifically warn that fracking in the semi-arid Karoo region would violate constitutional rights to water and a healthy environment. The document calls for the adoption of the precautionary principle, the implementation of long-term monitoring (up to 300 years) for well integrity, and the requirement for meaningful public participation and community development provisions.
Key insights
- Unconventional gas extraction contributes significantly to global warming through methane leakage, with shale gas production (fracking) showing leakage rates between 3.6% and 7.9%. A leakage rate of 2.7% is estimated to negate any climate benefits gas has over coal.
- Fracking is a water-intensive process that threatens South Africa's water-scarce environment. A single well can use up to 20 million litres of water, and in some regions, the average volume per hydraulic fracture is 42,500 m3.
- The Karoo region is particularly vulnerable because underground water is the primary source for all towns and activities in this semi-arid, drought-prone area, meaning fracking would place gas projects in direct competition with communities for water access.
- The proposed five-kilometre buffer zone for prohibited activities near waterworks, towns, and strategic water source areas is deemed arbitrary and insufficient because it ignores geological faults and subsurface fluid movement.
- There is a critical lack of state capacity for compliance monitoring and enforcement (CME). As of 2023, none of the 94 designated Environmental Mineral Resource Inspectors (EMRIs) are allocated to the oil and gas sector.
- The CER asserts that well integrity must be guaranteed and monitored for at least 300 years to prevent the long-term migration of poor-quality fluids into freshwater aquifers.
- The regulations are criticized for limited and discretionary public participation. The CER argues that meaningful consultation is essential for baseline monitoring plans and water use license applications.
Cite the original document
- APA
- Centre for Environmental Rights (2025). REGULATIONS FOR THE USE OF WATER FOR EXPLORATION AND PRODUCTION OF ONSHORE NATURALLY OCCURRING HYDROCARBONS THAT REQUIRE STIMULATION, INCLUDING HYDRAULIC FRACTURING AND UNDERGROUND COAL GASIFICATION, TO EXTRACT, AND ANY ACTIVITY INCIDENTAL THERETO THAT MAY IMPACT DETRIMENTALLY ON THE WATER RESOURCE. https://cer.org.za/wp-content/uploads/2025/04/CER-comments-on-the-Regulations-for-the-use-of-water-for-exploration-and-production-2024.pdf?x21779
- Chicago
- Centre for Environmental Rights. REGULATIONS FOR THE USE OF WATER FOR EXPLORATION AND PRODUCTION OF ONSHORE NATURALLY OCCURRING HYDROCARBONS THAT REQUIRE STIMULATION, INCLUDING HYDRAULIC FRACTURING AND UNDERGROUND COAL GASIFICATION, TO EXTRACT, AND ANY ACTIVITY INCIDENTAL THERETO THAT MAY IMPACT DETRIMENTALLY ON THE WATER RESOURCE. 2025. https://cer.org.za/wp-content/uploads/2025/04/CER-comments-on-the-Regulations-for-the-use-of-water-for-exploration-and-production-2024.pdf?x21779.
- Wikipedia
- {{cite press release |author=Centre for Environmental Rights |title=REGULATIONS FOR THE USE OF WATER FOR EXPLORATION AND PRODUCTION OF ONSHORE NATURALLY OCCURRING HYDROCARBONS THAT REQUIRE STIMULATION, INCLUDING HYDRAULIC FRACTURING AND UNDERGROUND COAL GASIFICATION, TO EXTRACT, AND ANY ACTIVITY INCIDENTAL THERETO THAT MAY IMPACT DETRIMENTALLY ON THE WATER RESOURCE |date=13 January 2025 |url=https://cer.org.za/wp-content/uploads/2025/04/CER-comments-on-the-Regulations-for-the-use-of-water-for-exploration-and-production-2024.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}
- BibTeX
- @misc{centreforenvironmentalrights2025regulations, author = {{Centre for Environmental Rights}}, title = {{REGULATIONS FOR THE USE OF WATER FOR EXPLORATION AND PRODUCTION OF ONSHORE NATURALLY OCCURRING HYDROCARBONS THAT REQUIRE STIMULATION, INCLUDING HYDRAULIC FRACTURING AND UNDERGROUND COAL GASIFICATION, TO EXTRACT, AND ANY ACTIVITY INCIDENTAL THERETO THAT MAY IMPACT DETRIMENTALLY ON THE WATER RESOURCE}}, publisher = {Centre for Environmental Rights}, year = {2025}, month = jan, url = {https://cer.org.za/wp-content/uploads/2025/04/CER-comments-on-the-Regulations-for-the-use-of-water-for-exploration-and-production-2024.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }
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