OBJECTIONS TO THE WATER USE LICENCE APPLICATION FOR THE PROPOSED MOKOLO CROCODILE RIVER (WEST) WATER AUGMENTATION PROJECT PHASE2A (MCWAP-2A)

The Centre for Environmental Rights (CER), on behalf of Earthlife Africa and groundWork, submitted formal objections on 14 June 2022 to the Integrated Water Use Licence Application (IWULA) for Phase 2A of the Mokolo Crocodile River (West) Water Augmentation Project (MCWAP-2A). The CER argues that the project is an unnecessary inter-basin transfer designed to support coal expansion, which contradicts South Africa's climate commitments and poses severe risks to aquatic ecosystems and local communities.

• The CER alleges a conflict of interest and a lack of procedural fairness because the Department of Water and Sanitation (DWS) acts as both the applicant and the decision-maker for the IWULA, which may constitute "actual and apparent bias in decision making".
• The IWULA is described as deficient for failing to address most of the statutory requirements under Section 27 of the National Water Act (NWA), with the CER noting that a "scant 3 page assessment" only briefly covers current water entitlements, socio-economic impacts, and strategic importance.
• The project is criticized for promoting the coal economy despite South Africa's commitment to a just transition and the Paris Agreement. The CER argues that new coal capacity is not necessary for the energy mix and risks becoming "stranded assets", potentially creating an "undue financial burden on the public".
• The CER contends that the use of water-intensive Wet Flue Gas Desulphurisation (WFGD) at the Medupi power station is not necessary, as Dry FGD technology is available, uses significantly less water (0.14l/kWh compared to 0.21l/kWh for WFGD), and produces no wastewater.
• Expert reviews indicate the project will severely impact aquatic ecosystems, potentially leading to a decline in species requiring high flows, increased salinity, and the proliferation of invasive species like the "Mosquito fish".
• The CER identifies significant knowledge gaps in the IWULA, including a lack of assessment regarding the Ecological Water Requirements (EWR), the Reserve, and the impacts of transferring poor-quality water from the Crocodile (West) River into the Matlabas River.
• The document asserts that the IWULA fails to consider South Africa's international obligations regarding shared watercourses, specifically the potential cumulative impacts on the water quality and levels of rivers in neighbouring countries via the Limpopo River.
• The project is accused of ignoring climate change impacts, with expert predictions for the Lephalale/Limpopo region (2021-2060) including the collapse of rain-fed agriculture, extreme heat making manual labour untenable, and increased food insecurity.

APA

Centre for Environmental Rights (2022). OBJECTIONS TO THE WATER USE LICENCE APPLICATION FOR THE PROPOSED MOKOLO CROCODILE RIVER (WEST) WATER AUGMENTATION PROJECT PHASE2A (MCWAP-2A). https://cer.org.za/wp-content/uploads/2022/06/CER-Objections-to-MCWAP-WUL-14.06.2022.pdf?x21779

Chicago

Centre for Environmental Rights. OBJECTIONS TO THE WATER USE LICENCE APPLICATION FOR THE PROPOSED MOKOLO CROCODILE RIVER (WEST) WATER AUGMENTATION PROJECT PHASE2A (MCWAP-2A). 2022. https://cer.org.za/wp-content/uploads/2022/06/CER-Objections-to-MCWAP-WUL-14.06.2022.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=OBJECTIONS TO THE WATER USE LICENCE APPLICATION FOR THE PROPOSED MOKOLO CROCODILE RIVER (WEST) WATER AUGMENTATION PROJECT PHASE2A (MCWAP-2A) |date=14 June 2022 |url=https://cer.org.za/wp-content/uploads/2022/06/CER-Objections-to-MCWAP-WUL-14.06.2022.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2022objections, author = {{Centre for Environmental Rights}}, title = {{OBJECTIONS TO THE WATER USE LICENCE APPLICATION FOR THE PROPOSED MOKOLO CROCODILE RIVER (WEST) WATER AUGMENTATION PROJECT PHASE2A (MCWAP-2A)}}, publisher = {Centre for Environmental Rights}, year = {2022}, month = jun, url = {https://cer.org.za/wp-content/uploads/2022/06/CER-Objections-to-MCWAP-WUL-14.06.2022.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }