NATURAL JUSTICE COMMENTARY ON THE INTENTION TO EXCLUDE THE DEVELOPMENT AND EXPANSION OF SOLAR PHOTOVOLTAIC INSTALLATIONS FROM THE REQUIREMENT TO OBTAIN AN ENVIRONMENTAL AUTHORIZATION BASED ON COMPLIANCE WITH AN ADOPTED ENVIRONMENTAL MANAGEMENT INSTRUMENT GAZETTED NO. 46871 OF 08/SEP/2022 AND THE INTENTION TO ADOPT THE NATIONAL WEB-BASED ENVIRONMENTAL SCREENING TOOL AS AN ENVIRONMENTAL MANAGEMENT INSTRUMENT (SCREENING TOOL)

Natural Justice opposes the South African government's intention to exclude solar photovoltaic (PV) installations from environmental authorization requirements via a web-based screening tool. The organization argues that this 'blanket and overbroad exclusion' violates constitutional rights to administrative justice, public participation, and a healthy environment. They highlight risks including cumulative environmental impacts, infringement on community land rights, and potential social backlash that could ultimately hinder the energy transition. Natural Justice recommends prioritizing the use of degraded lands, such as brownfields and unrehabilitated mining sites, for solar deployment while maintaining meaningful public consultation.

• The proposed exclusion of solar PV installations from the environmental impact assessment (EIA) process is viewed as a violation of constitutional rights to just administrative action and public participation, potentially leading to increased litigation and project delays.
• While solar PV is cleaner than fossil fuels, medium- and large-scale projects can still cause significant environmental harm, including land clearing, habitat fragmentation, and the potential for soil and water contamination from toxic materials in panels.
• The proposed web-based screening tool fails to account for cumulative impacts of multiple projects in one area and lacks a methodology to evaluate the environmental footprint of associated linear infrastructure like transmission and distribution lines.
• The exclusion poses a risk to community land rights and tenure security, particularly given South Africa's history of land appropriation from indigenous and local communities.
• The screening tool is deficient regarding water security, as it does not specifically evaluate areas subject to periodic drought or the water requirements needed for cleaning solar panels in a water-scarce country.
• Natural Justice suggests that the government should instead expedite solar deployment by prioritizing 'brownfield' sites, such as unrehabilitated mining sites, landfills, and industrial land, rather than exempting projects from environmental oversight.

APA

Natural Justice (n.d.). NATURAL JUSTICE COMMENTARY ON THE INTENTION TO EXCLUDE THE DEVELOPMENT AND EXPANSION OF SOLAR PHOTOVOLTAIC INSTALLATIONS FROM THE REQUIREMENT TO OBTAIN AN ENVIRONMENTAL AUTHORIZATION BASED ON COMPLIANCE WITH AN ADOPTED ENVIRONMENTAL MANAGEMENT INSTRUMENT GAZETTED NO. 46871 OF 08/SEP/2022 AND THE INTENTION TO ADOPT THE NATIONAL WEB-BASED ENVIRONMENTAL SCREENING TOOL AS AN ENVIRONMENTAL MANAGEMENT INSTRUMENT (SCREENING TOOL). https://naturaljustice.org/wp-content/uploads/2022/10/Comment-on-the-Intention-to-Exclude-Solar-Photovoltaic-Energy-Installation.pdf

Chicago

Natural Justice. NATURAL JUSTICE COMMENTARY ON THE INTENTION TO EXCLUDE THE DEVELOPMENT AND EXPANSION OF SOLAR PHOTOVOLTAIC INSTALLATIONS FROM THE REQUIREMENT TO OBTAIN AN ENVIRONMENTAL AUTHORIZATION BASED ON COMPLIANCE WITH AN ADOPTED ENVIRONMENTAL MANAGEMENT INSTRUMENT GAZETTED NO. 46871 OF 08/SEP/2022 AND THE INTENTION TO ADOPT THE NATIONAL WEB-BASED ENVIRONMENTAL SCREENING TOOL AS AN ENVIRONMENTAL MANAGEMENT INSTRUMENT (SCREENING TOOL). n.d. https://naturaljustice.org/wp-content/uploads/2022/10/Comment-on-the-Intention-to-Exclude-Solar-Photovoltaic-Energy-Installation.pdf.

Wikipedia

{{cite press release |author=Natural Justice |title=NATURAL JUSTICE COMMENTARY ON THE INTENTION TO EXCLUDE THE DEVELOPMENT AND EXPANSION OF SOLAR PHOTOVOLTAIC INSTALLATIONS FROM THE REQUIREMENT TO OBTAIN AN ENVIRONMENTAL AUTHORIZATION BASED ON COMPLIANCE WITH AN ADOPTED ENVIRONMENTAL MANAGEMENT INSTRUMENT GAZETTED NO. 46871 OF 08/SEP/2022 AND THE INTENTION TO ADOPT THE NATIONAL WEB-BASED ENVIRONMENTAL SCREENING TOOL AS AN ENVIRONMENTAL MANAGEMENT INSTRUMENT (SCREENING TOOL) |url=https://naturaljustice.org/wp-content/uploads/2022/10/Comment-on-the-Intention-to-Exclude-Solar-Photovoltaic-Energy-Installation.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{naturaljusticendnatural, author = {{Natural Justice}}, title = {{NATURAL JUSTICE COMMENTARY ON THE INTENTION TO EXCLUDE THE DEVELOPMENT AND EXPANSION OF SOLAR PHOTOVOLTAIC INSTALLATIONS FROM THE REQUIREMENT TO OBTAIN AN ENVIRONMENTAL AUTHORIZATION BASED ON COMPLIANCE WITH AN ADOPTED ENVIRONMENTAL MANAGEMENT INSTRUMENT GAZETTED NO. 46871 OF 08/SEP/2022 AND THE INTENTION TO ADOPT THE NATIONAL WEB-BASED ENVIRONMENTAL SCREENING TOOL AS AN ENVIRONMENTAL MANAGEMENT INSTRUMENT (SCREENING TOOL)}}, publisher = {Natural Justice}, url = {https://naturaljustice.org/wp-content/uploads/2022/10/Comment-on-the-Intention-to-Exclude-Solar-Photovoltaic-Energy-Installation.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }