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The Centre for Environmental Rights (CER) submitted comments on the South African National Petroleum Company Bill, B2 - 2026, arguing that the draft legislation prioritizes petroleum expansion and commercialization over environmental governance, climate commitments, and constitutional rights. While acknowledging the potential for improved coordination by consolidating PetroSA, iGas, and the Strategic Fuel Fund, the CER recommends rejecting the Bill in its current form until significant amendments are made to align it with South Africa's climate obligations and environmental laws.

A submission by a coalition of civil society organisations—including Law for Energy Transitions Africa, Natural Justice, The Green Connection, and Project 90 by 2030—providing detailed comments on the draft South African Wholesale Electricity Market (SAWEM) Code and Rules. The submission argues that the draft framework lacks sufficient alignment with constitutional rights and climate obligations, suffers from governance conflicts of interest due to the Market Operator's link to Eskom, and lacks transparency regarding costs and contracts.

The Centre for Environmental Rights (CER) submitted comments on the Draft Mineral Resources Development Bill, 2025, arguing that the Bill fails to adequately protect communities and the environment. The CER criticizes the 'One Environmental System' for creating a conflict of mandate within the Department of Mineral and Petroleum Resources, advocates for the adoption of 'free, prior and informed consent' for communities, and warns that shortened timelines for environmental authorizations and consultations risk reducing public participation to a 'tick-box exercise'.

The Centre for Environmental Rights (CER) submitted comments on January 13, 2025, regarding the Department of Water and Sanitation's (DWS) proposed regulations for water use in onshore hydrocarbon exploration and production, specifically hydraulic fracturing (fracking) and underground coal gasification (UCG). The CER argues that the regulations are insufficient to protect water resources, fail to adequately address climate change and methane leakage, and lack robust compliance monitoring and enforcement mechanisms. They specifically highlight the risks to the water-scarce Karoo region and call for more stringent buffer zones, longer-term monitoring of well integrity, and mandatory community development provisions.

This policy brief by the Center for International Environmental Law (CIEL) provides a detailed analysis and commentary on the Revised Zero Draft of the international plastics treaty. It evaluates various options for the treaty's structure and obligations, advocating for legally binding mandates ('shall' instead of 'should'), a full life-cycle approach to plastic pollution, and the inclusion of human rights and health dimensions. CIEL emphasizes the necessity of controlling primary plastic polymer production and eliminating hazardous chemicals to achieve the treaty's objective of ending plastic pollution.

This document contains joint comments submitted by the Centre for Environmental Rights (CER) and seven other civil society organisations to the South African Department of Forestry, Fisheries, and the Environment (DFFE). The submission critiques the proposed 2022 regulations regarding financial provisioning for the mitigation and rehabilitation of environmental damage caused by extractive activities, arguing that the regulations should prioritise environmental protection and community rights over corporate profitability.

Natural Justice submitted comments on the draft Climate Change Bill (B9-2022) to the South African Portfolio Committee on Environment, Forestry and Fisheries on 27 May 2022. The organization argues that the Bill lacks the urgency required to address the climate crisis, fails to set ambitious emission reduction targets, and provides insufficient protections for constitutional rights and vulnerable communities.

Natural Justice provides a detailed critique of Mozambique's preliminary draft Forestry Bill (April 2022), arguing that the document functions more as an economic instrument for logging and trade than a tool for environmental protection. The organization highlights critical gaps in the bill regarding sustainable forest management, community rights, biodiversity protection, and the prevention of institutional corruption.

The Centre for Environmental Rights (CER), on behalf of the Life After Coal Campaign (LAC), submitted comments on the Second Amendment Bill of the Electricity Regulation Act (ERA) 94 of 2006. The CER argues that the amendments fail to integrate climate change obligations and a just transition, while granting excessive discretionary power to the Minister of Mineral Resources and Energy. The submission calls for stronger regulatory oversight by NERSA, increased transparency in licensing and procurement, and the protection of public participation rights in line with PAJA and PAIA.

A joint submission by seven civil society organisations, led by the Centre for Environmental Rights, providing detailed comments and proposed amendments to the 2021 draft regulations on financial provision for the mitigation and rehabilitation of environmental damage caused by mining and energy operations in South Africa.

The Centre for Environmental Rights (CER) provided written comments on the Draft National Mine Closure Strategy 2021, published by the Department of Mineral Resources and Energy (DMRE). While supporting the initiative to increase certainty in mine closure and rehabilitation, the CER argues that the strategy must better protect mining-affected communities, ensure meaningful public participation from the pre-feasibility stage, and align strictly with existing environmental legislation like the National Environmental Management Act (NEMA).

The Centre for Environmental Rights (CER) submitted comments on June 7, 2021, regarding the draft Regulations for the use of water for gas exploration and production in South Africa. While welcoming the goal of protecting water resources, the CER argues that the draft regulations are insufficient to protect surface and underground water from the risks of hydraulic fracturing and underground coal gasification (UCG), particularly in the context of climate change.

Natural Justice submitted a set of proposed amendments to the Kenya Forest Service regarding the Forests (Community Participation in Sustainable Forest Management) Rules, 2009. The organization advocates for greater transparency, the inclusion of private sector actors in forest conservation, and the mandatory participation of forest associations to align with constitutional requirements.

The Centre for Environmental Rights (CER) provides a supplementary table of comments on the National Environmental Management Laws Amendment Bill, 2017 [B14D-2017]. The document details proposed amendments to several South African environmental laws, including the National Environmental Management Act (NEMA), the Protected Areas Act (NEMPAA), and the Integrated Coastal Management Act (NEMICMA), offering specific critiques and alternative wording to strengthen environmental protection and enforcement.

The Centre for Environmental Rights (CER) provides a detailed table of comments and proposed amendments to the National Environmental Management Laws Amendment Bill, 2017. The document focuses on strengthening the National Environmental Management: Air Quality Act, 2004 (NEMAQA) and the National Environmental Management: Waste Act, 2008 (NEMWA), specifically regarding air quality governance, atmospheric emission licences (AELs), and the management of contaminated land.

The Centre for Environmental Rights (CER), representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted detailed comments on the Climate Change Bill, 2018. The CER argues that the Bill focuses too heavily on government bureaucracy and fails to address the urgency of the climate crisis or provide sufficient mechanisms for holding emitters accountable. Key recommendations include setting a strict, legally binding emissions trajectory aligned with the Paris Agreement, ensuring full public disclosure of carbon budgets and GHG reports, and establishing independent oversight and appeals bodies.

The Centre for Environmental Rights (CER) and Greenpeace Africa submitted joint comments on the Draft Carbon Tax Bill, 2017, arguing that the proposed tax rate and extensive allowances are insufficient to incentivize a transition to energy efficiency or meaningfully reduce South Africa's greenhouse gas (GHG) emissions.

The Centre for Environmental Rights (CER) provides critical feedback on the Department of Water and Sanitation's (DWS) draft Mine Water Management Policy Position. The CER argues that the draft understates the crisis of mine water management in South Africa, citing a systemic failure in mine closures and a lack of compliance monitoring and enforcement. The CER recommends that the DWS utilize existing legislative tools—specifically the National Water Act (NWA), the National Environmental Management Act (NEMA), and the Mineral and Petroleum Resources Development Act (MPRDA)—to enforce the 'polluter pays' principle and secure financial provisions for water treatment before granting licenses.

The Center for International Environmental Law argues that the Trump Administration's intention to withdraw the United States from the Paris Agreement violates international law, damages US global credibility, and slows the urgent response to climate change without benefiting the coal or fossil fuel industries.

The Centre for Environmental Rights (CER) submitted comments on November 9, 2015, regarding draft regulations for determining administrative fines under section 22A of the National: Environmental Management: Air Quality Act (AQA). The CER argues that the draft regulations lack consistency with other environmental fine mechanisms and fail to provide for public participation, proposing specific amendments to the fine calculation and the inclusion of aggravating factors.