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SUBMISSIONS ON THE DRAFT NATIONAL WATER RESOURCES STRATEGY-3 PUBLISHED IN GOVERNMENT GAZETTE 47133 ON 29 JULY 2022

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The Centre for Environmental Rights (CER) submitted comments on the draft National Water Resources Strategy 3 (NWRS-3) on 28 October 2022. The submission argues that the strategy must move beyond treating climate change as a future uncertainty and instead implement binding regulations to protect water security. The CER emphasizes the need for legal protection of Strategic Water Source Areas (SWSAs), strengthened compliance monitoring and enforcement (CME), increased transparency in water resource information, and a precautionary approach to unconventional oil and gas exploration due to risks of water contamination and greenhouse gas emissions.

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  • The CER argues that the draft NWRS-3 treats climate change primarily as a future threat and relies too heavily on the development of further policies and guidelines rather than implementing binding regulations, despite existing knowledge of the crisis.
  • Climate change is expected to severely impact South African water resources through reduced rainfall, increased evaporation, and more frequent and intense long-duration droughts and heat waves, which may overwhelm existing coping mechanisms.
  • The CER calls for the NWRS-3 to prioritize the protection and rehabilitation of wetlands due to their critical role in climate change adaptation and their ability to mitigate flash floods and droughts.
  • The CER advocates for the formal legal protection of Strategic Water Source Areas (SWSAs) to ensure water security, noting that these assets remain threatened by water-intensive and polluting activities such as coal mining.
  • To improve the regulation of the water sector, the CER recommends strengthening Compliance Monitoring and Enforcement (CME) by increasing the resources and expertise of the 'Blue Scorpions', improving whistleblowing mechanisms, and publishing CME results in annual reports.
  • The CER identifies a lack of transparency in the Department of Water and Sanitation (DWS) and requests that water use licences, monitoring results, and inspection reports be made publicly available on the DWS website.
  • The CER warns that unconventional oil and gas activities pose serious threats to water sources through high water demand and contamination, and suggests a ban or moratorium on such exploration until further studies are conducted.

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APA
Centre for Environmental Rights (2022). SUBMISSIONS ON THE DRAFT NATIONAL WATER RESOURCES STRATEGY-3 PUBLISHED IN GOVERNMENT GAZETTE 47133 ON 29 JULY 2022. https://cer.org.za/wp-content/uploads/2022/10/CER-submission-on-the-Draft-National-Water-Resource-Strategy-3_28-10-22.pdf?x21779
Chicago
Centre for Environmental Rights. SUBMISSIONS ON THE DRAFT NATIONAL WATER RESOURCES STRATEGY-3 PUBLISHED IN GOVERNMENT GAZETTE 47133 ON 29 JULY 2022. 2022. https://cer.org.za/wp-content/uploads/2022/10/CER-submission-on-the-Draft-National-Water-Resource-Strategy-3_28-10-22.pdf?x21779.
Wikipedia
{{cite press release |author=Centre for Environmental Rights |title=SUBMISSIONS ON THE DRAFT NATIONAL WATER RESOURCES STRATEGY-3 PUBLISHED IN GOVERNMENT GAZETTE 47133 ON 29 JULY 2022 |date=28 October 2022 |url=https://cer.org.za/wp-content/uploads/2022/10/CER-submission-on-the-Draft-National-Water-Resource-Strategy-3_28-10-22.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}
BibTeX
@misc{centreforenvironmentalrights2022submissions, author = {{Centre for Environmental Rights}}, title = {{SUBMISSIONS ON THE DRAFT NATIONAL WATER RESOURCES STRATEGY-3 PUBLISHED IN GOVERNMENT GAZETTE 47133 ON 29 JULY 2022}}, publisher = {Centre for Environmental Rights}, year = {2022}, month = oct, url = {https://cer.org.za/wp-content/uploads/2022/10/CER-submission-on-the-Draft-National-Water-Resource-Strategy-3_28-10-22.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }

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