COMMENTS ON THE DRAFT SCOPING REPORT FOR THE PROPOSED MOKOLO AND CROCODILE RIVER (WEST) WATER AUGMENTATION PROJECT (PHASE 2)

The Centre for Environmental Rights (CER), acting for Earthlife Africa NPC and groundWork, submitted comments on 11 April 2018 regarding the draft Scoping Report for the Mokolo and Crocodile River (West) Water Augmentation Project (Phase 2) (MCWAP-2). The CER argues that the project is based on outdated assumptions regarding South Africa's energy needs and fails to adequately assess climate change, water reserves, and indirect environmental and health impacts.

• The Scoping Report fails to allocate water for the 'Reserve', a legal requirement under the National Water Act, 1998, which takes precedence over all other water uses.
• The CER argues that the Scoping Report's approach to climate change is insufficient and legally flawed, failing to meet the standards set by the Thabametsi judgment which requires a comprehensive climate change impact assessment (CCIA).
• Scientific evidence suggests that climate change will likely reduce water flow in the Mokolo and Crocodile (West) Rivers due to higher evaporation and flash droughts, threatening the project's long-term viability.
• The project would enable the growth of coal-fired power stations and mines, which the CER claims will significantly increase South Africa's greenhouse gas emissions and conflict with the Paris Agreement.
• The document highlights risks of water pollution from the project's enabled developments, specifically acid mine drainage (AMD) and the leaching of toxic metals from coal ash residue into groundwater and surface water.
• The CER contends that the public participation process was inadequate, providing only one month for comments on the Scoping Report and allowing the DWS only one week to address those comments before submission to the DEA.

APA

Centre for Environmental Rights (2018). COMMENTS ON THE DRAFT SCOPING REPORT FOR THE PROPOSED MOKOLO AND CROCODILE RIVER (WEST) WATER AUGMENTATION PROJECT (PHASE 2). https://cer.org.za/wp-content/uploads/2018/04/MCWAP-2-SCOPING-REPORT-COMMENTS-11-4-18.pdf?x21779

Chicago

Centre for Environmental Rights. COMMENTS ON THE DRAFT SCOPING REPORT FOR THE PROPOSED MOKOLO AND CROCODILE RIVER (WEST) WATER AUGMENTATION PROJECT (PHASE 2). 2018. https://cer.org.za/wp-content/uploads/2018/04/MCWAP-2-SCOPING-REPORT-COMMENTS-11-4-18.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=COMMENTS ON THE DRAFT SCOPING REPORT FOR THE PROPOSED MOKOLO AND CROCODILE RIVER (WEST) WATER AUGMENTATION PROJECT (PHASE 2) |date=11 April 2018 |url=https://cer.org.za/wp-content/uploads/2018/04/MCWAP-2-SCOPING-REPORT-COMMENTS-11-4-18.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2018comments, author = {{Centre for Environmental Rights}}, title = {{COMMENTS ON THE DRAFT SCOPING REPORT FOR THE PROPOSED MOKOLO AND CROCODILE RIVER (WEST) WATER AUGMENTATION PROJECT (PHASE 2)}}, publisher = {Centre for Environmental Rights}, year = {2018}, month = apr, url = {https://cer.org.za/wp-content/uploads/2018/04/MCWAP-2-SCOPING-REPORT-COMMENTS-11-4-18.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }