-1

Natural Justice submitted comments to the South African Department of Transport regarding the Marine Pollution (Prevention of Pollution from Ships) Amendment Bill (B5-2022). The organization argues that the Bill should implement stronger penalties, increase local government and police involvement in enforcement, and remove broad exemptions for ship trials and offshore mineral processing to align with South Africa's Paris Agreement commitments.

• Natural Justice supports the increase of the maximum fine from R500,000 to R10,000,000 and the maximum prison sentence from five to ten years, but argues that the fine cap should be further raised or removed entirely because pollution costs can exceed R10 million.
• To enhance deterrence, Natural Justice suggests the Bill should either create a separate offense for persistent disobedience—similar to the Canada Shipping Act, 2001, which holds parties accountable for each day of violation—or establish a minimum penalty, citing China's Marine Environment Protection Law as an example.
• The organization recommends expanding enforcement capabilities by granting nominated surveyors the authority to immediately detain and remove vessels, and by including police and local authorities as surveyors to improve monitoring and response.
• Natural Justice argues that the Bill lacks a centralized enforcement agency, unlike land-based conservation regulated by the Department of Forestry, Fisheries, and Environment under the National Environmental Management Act 107 of 1998.
• The organization opposes a provision that exempts ship trials from certain Annex provisions for up to five years, stating it is "overly broad" and conflicts with South Africa's Paris Agreement pledge to reduce carbon emissions by 50%.
• Natural Justice calls for the total repeal of the absolute exemption for emissions from the exploration, exploitation, and offshore processing of sea-bed mineral resources, arguing it incentivizes the fossil fuel industry and contradicts energy transition goals.
• The submission notes that the Minister failed to consult local communities, specifically those in South Durban and the Western Coast, during the drafting of the Bill, and asserts that the Bill should be referred to the National House of Traditional Leaders.

APA

Natural Justice (n.d.). -1. https://naturaljustice.org/wp-content/uploads/2022/10/Comments-on-Marine-Pollution-Amendment-Bill-B5-2022.pdf

Chicago

Natural Justice. -1. n.d. https://naturaljustice.org/wp-content/uploads/2022/10/Comments-on-Marine-Pollution-Amendment-Bill-B5-2022.pdf.

Wikipedia

{{cite press release |author=Natural Justice |title=-1 |url=https://naturaljustice.org/wp-content/uploads/2022/10/Comments-on-Marine-Pollution-Amendment-Bill-B5-2022.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{naturaljusticend, author = {{Natural Justice}}, title = {{-1}}, publisher = {Natural Justice}, url = {https://naturaljustice.org/wp-content/uploads/2022/10/Comments-on-Marine-Pollution-Amendment-Bill-B5-2022.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }