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The IEJ criticizes the 2026 draft SRD grant regulations for ignoring long-standing systemic flaws, such as the inadequate grant value of R370 and restrictive online-only applications. While welcoming the extension of the grant to March 2027, the IEJ warns that this period expires before the planned introduction of the Basic Income Support (BIS) policy in March 2027. The submission advocates for a transition to a universal basic income, the use of self-declarations over inaccurate database verifications, and an increase in the grant value to meet the food poverty line of R855.

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 document argues that the proposed amendments to the EIA Regulations 2014 would lower the required level of environmental assessment for onshore exploration and seismic surveys, potentially ignoring significant climate and ecological risks. It specifically criticizes the shift of onshore exploration to Listing Notice 1, which only requires a Basic Assessment Report (BAR) rather than a full Scoping and Environmental Impact Assessment (S&EIA). The authors also express concern over the Upstream Petroleum Resources Development Act (UPRDA) and the potential for 'petroleum rights' to create regulatory gaps. Additionally, the submission advocates for more stringent regulation of the reclamation of residue stockpiles and deposits, arguing they should be treated as distinct activities due to their toxic nature. The document further suggests that the appointment of Environmental Assessment Practitioners (EAPs) should be handled by the Minister or EAPASA to ensure independence from proponents.

The Centre for Environmental Rights (CER) argues that the proposed 2024 regulations for unconventional hydrocarbon extraction in South Africa are insufficient to protect water resources and the climate. The CER highlights the extreme water intensity of fracking, the risk of groundwater contamination from toxic chemicals and radioactive materials, and the lack of state capacity for compliance monitoring. They specifically warn that fracking in the semi-arid Karoo region would violate constitutional rights to water and a healthy environment. The document calls for the adoption of the precautionary principle, the implementation of long-term monitoring (up to 300 years) for well integrity, and the requirement for meaningful public participation and community development provisions.

The Centre for Environmental Rights (CER), on behalf of groundWork and Earthlife Africa, submits a formal objection to Eskom's application for exemptions from Minimum Emission Standards (MES) for eight coal-fired power stations under section 59 of the Air Quality Act (AQA). The submission argues that these exemptions violate the constitutional right to a healthy environment, particularly for residents in Priority Areas, and that Eskom has failed to justify its 14-year delay in achieving compliance.

The Centre for Environmental Rights (CER), on behalf of the Life After Coal (LAC) coalition, submitted comments on the Gas Amendment Bill [B – 2023], arguing that accelerating gas infrastructure is irrational given the climate emergency and South Africa's extreme vulnerability to climate change. The submission criticizes the Bill for inadequate public consultation processes, lack of transparency regarding confidential information, and a failure to align with international climate targets such as the IPCC's 1.5°C benchmark.

The Southeast Alaska Indigenous Transboundary Commission (SEITC) is seeking relief from the Inter-American Commission on Human Rights due to the impacts of hard-rock mining in British Columbia, Canada. The document argues that mining projects in the Taku, Stikine, and Unuk watersheds threaten the subsistence and cultural rights of Southeast Alaska Native communities through heavy metal pollution and habitat destruction. SEITC alleges that Canada and B.C. have failed to conduct comprehensive transboundary environmental assessments, have ignored the need for free, prior, and informed consent (FPIC), and have used a flawed amendment process to expand mine operations without adequate scrutiny. The submission introduces a new claim regarding the violation of the right to a healthy environment and requests that the Commission investigate these claims and recommend the suspension of mine authorizations until transboundary harms are addressed.

The Centre for Environmental Rights argues that several proposed amendments to South Africa's EIA Regulations underestimate the environmental risks of mining and seismic activities. Specifically, it contends that onshore seismic surveys and the expansion of mining operations—including the reclamation of residue stockpiles—should require a full Scoping and Environmental Impact Assessment (S&EIA) under Listing Notice 2 rather than a Basic Assessment Report under Listing Notice 1. The submission also highlights systemic issues in the EIA process, such as the lack of transparency in mining right amendments under section 102 of the MPRDA and the conflict of interest arising from applicants paying for their own Environmental Assessment Practitioners (EAPs).

The submission argues that several proposed amendments to the Public Service Regulations undermine accountability and the fight against corruption. Key objections include the withdrawal of prohibitions on public servants doing business with the state and the removal of reporting obligations for executive authorities. The authors propose strengthening oversight by requiring the publication of organizational structures and human resource plans on department websites, increasing prohibition periods for employees dismissed for misconduct, and ensuring the Auditor-General is notified of law enforcement referrals.

The submission by IEJ and SERI criticizes the South African government's limited amendments to the SRD grant regulations, which only extended the expiry date to March 2024. The authors argue that the R350 grant value is arbitrary and eroded by inflation, and that the means-test threshold of R624 is too low. They highlight systemic exclusions caused by flawed bank and database verification, digital barriers in online-only applications, and a restrictive appeals process. The document recommends transitioning the SRD grant into a permanent Universal Basic Income (UBI) indexed to the upper-bound poverty line (UBPL) of R1417, removing the budget cap, and eliminating work conditionality clauses to ensure the right to social assistance is progressively realized.

The CER's submission on the draft NWRS-3 argues that the strategy must move beyond treating climate change as a future threat and instead implement binding regulations to protect water security. The CER advocates for the formal legal protection of Strategic Water Source Areas (SWSAs), strengthened compliance monitoring and enforcement (CME) through the 'Blue Scorpions', and a moratorium on unconventional oil and gas exploration due to risks of water contamination and methane emissions. It further emphasizes the need for transparency in water licensing and the alignment of the NWRS-3 with South Africa's international commitments under the Paris Agreement and the domestic Climate Change Bill.

The Centre for Environmental Rights (CER) critiques the Western Cape's draft climate plan, arguing for greater urgency, transparency, and meaningful public participation. The CER strongly opposes the use of fossil gas as a transition fuel due to methane leakage and warns against the potential misuse of 'Net Zero' targets. They propose a comprehensive set of 27 guiding principles for the plan's implementation, emphasizing climate justice, the phase-out of fossil fuels, and the protection of vulnerable groups, particularly those in informal settlements.

The document argues that the procurement of 3,000 MW of gas power is irrational, unlawful, and environmentally harmful. It claims the process was 'tailor-made' for an existing Eskom project, lacked adequate public consultation, and ignores the availability of cheaper, cleaner renewable energy alternatives. The authors assert that gas is not a 'bridging fuel' due to high methane leakage and that such infrastructure risks becoming a stranded asset, thereby threatening South Africa's climate commitments and constitutional rights to a healthy environment.

The Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, represented by the Centre for Environmental Rights, groundWork, and Earthlife Africa, submitted comments on the Climate Change Bill, 2022. The submission argues that the Bill is insufficient to address the climate emergency and lacks the urgency, ambition, and enforcement mechanisms necessary to meet South Africa's international obligations under the Paris Agreement and protect constitutional rights.

Natural Justice argues that South Africa's Gas Master Plan is incompatible with the country's climate commitments and the Climate Change Bill. The submission highlights risks including fugitive methane emissions, fossil fuel dependency, and the potential for inadequate compensation for land expropriation. It calls for a transition toward renewable energy, the adoption of the 'free prior and informed consent' (FPIC) principle for affected communities, and a more transparent public participation process.

The CER and groundWork oppose the Gas Amendment Bill [B9-2020], asserting that it facilitates fossil fuel development contrary to South Africa's climate obligations and the 1.5°C target. They argue the Bill lacks meaningful public consultation, fails to provide adequate access to information, and irregularly grants environmental regulatory powers to the Energy Regulator, thereby encroaching on the mandate of the Minister of Forestry, Fisheries and Environment.

Natural Justice submits a series of proposed amendments to the Wildlife Conservation and Management Act No. 47 of 2013. The organization argues for a 'human-rights approach to conservation' and the inclusion of 'access to information' and 'access to justice' as guiding principles. Key recommendations include establishing an external auditing authority for the wildlife service to prevent abuse of licensing powers, ensuring the inclusion of socially excluded groups (such as women, youth, and indigenous communities) in County Wildlife Conservation and Compensation Committees, and requiring that the declaration of protected areas incorporate local community traditional knowledge. The submission also highlights the need to protect wildlife migratory corridors from state-led and private development projects and calls for clearer guidelines on bioprospecting and the monitoring of offenses within private conservation systems.

The Centre for Environmental Rights (CER) submits that the draft Upstream Petroleum Resources Development Bill, 2019 is deficient in its approach to the climate crisis and community welfare. The CER argues that gas exploration and production pose severe risks to climate, air, water, and marine environments, and that the Bill's consultation processes are 'woefully inadequate'. Furthermore, the CER criticizes the lack of a robust Social and Labour Plan (SLP) framework to ensure benefits reach affected communities, noting that a proposed 20% state carried interest is an insufficient substitute for local development. The submission also calls for stronger administrative penalties to ensure corporate compliance with environmental laws.

The Centre for Environmental Rights (CER), writing on behalf of the Life After Coal Campaign, submitted comments to the National Energy Regulator of South Africa (NERSA) regarding a draft ministerial determination to procure 2,000 MW of new generation capacity. The CER argues that this procurement must prioritize clean, affordable, and renewable energy sources over fossil fuels to align with constitutional obligations and public interest, while criticizing the lack of transparency regarding Request for Information (RFI) responses and the inadequacy of the public consultation process.

This document contains legal submissions by a coalition of eight environmental organisations, represented by the Centre for Environmental Rights, appealing a decision by the Gert Sibande District Joint Municipal Planning Tribunal. The appeal seeks to revoke the approval of a land-use change application by Atha-Africa Ventures (Pty) Ltd to enable the construction of the Yzermyn Underground Coal Mine on Portion 1 of the farm Yzermyn 96 HT, arguing that the decision is unlawful, environmentally catastrophic, and contrary to national water security interests.