COMMENT ON THE CONSULTATION ON THE INTENTION TO PRESCRIBE MINIMUM INFORMATION REQUIREMENTS FOR BASELINE MONITORING FOR ONSHORE EXPLORATION OPERATIONS PUBLISHED ON 7 NOVEMBER 2025 IN GOVERNMENT GAZETTE NO. 6811 UNDER GOVERNMENT NOTICE NO. 53637

The Centre for Environmental Rights (CER) and Natural Justice (NJ) argue that the proposed MIR for onshore exploration in South Africa lacks the specificity, enforceable standards, and climate integration necessary to protect environmental integrity and community interests. They recommend mandatory greenhouse gas accounting, a regional cumulative impact assessment, and a comprehensive public health baseline. Technical experts in the document highlight critical gaps in groundwater monitoring, the absence of a risk-based 'traffic light protocol' for induced seismicity, and the need for transparent chemical disclosure of fracturing fluids. The authors ultimately argue that hydraulic fracturing is incompatible with South Africa's climate commitments and water scarcity, suggesting it should be prohibited.

• The proposed MIR lacks explicit requirements for strategic climate or cumulative-impact assessments, omitting greenhouse-gas budget analysis and climate risk assessments despite South Africa's national climate obligations.
• The authors recommend the inclusion of 'project greenhouse-gas (GHG) accounting' to quantify total life-cycle emissions (Scope 1, 2, and material Scope 3) to align the MIR with the Climate Change Act, 2024 and Paris Agreement NDCs.
• The proposed regulatory framework for induced seismicity is based on outdated science and lacks a 'traffic light protocol' (TLP) to manage risks of human-caused earthquakes in the Karoo Basin.
• There is a significant 'Health Governance Gap' in the MIR, as it does not require a comprehensive Health Impact Assessment (HIA) or baseline health status assessments beyond general respiratory health.
• Socio-economic baseline monitoring is limited to 'statistics gathering' and fails to map household-level livelihood dependencies, food security, or market access for rural communities.
• The authors argue that hydraulic fracturing should be prohibited in South Africa due to climate incompatibility, water unsustainability, and the risk of irreversible aquifer contamination.

APA

Centre for Environmental Rights (2026). COMMENT ON THE CONSULTATION ON THE INTENTION TO PRESCRIBE MINIMUM INFORMATION REQUIREMENTS FOR BASELINE MONITORING FOR ONSHORE EXPLORATION OPERATIONS PUBLISHED ON 7 NOVEMBER 2025 IN GOVERNMENT GAZETTE NO. 6811 UNDER GOVERNMENT NOTICE NO. 53637. https://cer.org.za/wp-content/uploads/2026/04/No.-6811-CER-NJ-comments-13.02.2026.pdf?x21779

Chicago

Centre for Environmental Rights. COMMENT ON THE CONSULTATION ON THE INTENTION TO PRESCRIBE MINIMUM INFORMATION REQUIREMENTS FOR BASELINE MONITORING FOR ONSHORE EXPLORATION OPERATIONS PUBLISHED ON 7 NOVEMBER 2025 IN GOVERNMENT GAZETTE NO. 6811 UNDER GOVERNMENT NOTICE NO. 53637. 2026. https://cer.org.za/wp-content/uploads/2026/04/No.-6811-CER-NJ-comments-13.02.2026.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=COMMENT ON THE CONSULTATION ON THE INTENTION TO PRESCRIBE MINIMUM INFORMATION REQUIREMENTS FOR BASELINE MONITORING FOR ONSHORE EXPLORATION OPERATIONS PUBLISHED ON 7 NOVEMBER 2025 IN GOVERNMENT GAZETTE NO. 6811 UNDER GOVERNMENT NOTICE NO. 53637 |date=13 February 2026 |url=https://cer.org.za/wp-content/uploads/2026/04/No.-6811-CER-NJ-comments-13.02.2026.pdf?x21779 |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2026comment, author = {{Centre for Environmental Rights}}, title = {{COMMENT ON THE CONSULTATION ON THE INTENTION TO PRESCRIBE MINIMUM INFORMATION REQUIREMENTS FOR BASELINE MONITORING FOR ONSHORE EXPLORATION OPERATIONS PUBLISHED ON 7 NOVEMBER 2025 IN GOVERNMENT GAZETTE NO. 6811 UNDER GOVERNMENT NOTICE NO. 53637}}, publisher = {Centre for Environmental Rights}, year = {2026}, month = feb, url = {https://cer.org.za/wp-content/uploads/2026/04/No.-6811-CER-NJ-comments-13.02.2026.pdf?x21779}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }