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DRAFT NATIONAL WATER RESOURCE STRATEGY 2ND EDITION
The CER evaluates the draft NWRS2 against its previous 'Stop Treading Water' report, supporting goals to improve Department of Water Affairs (DWA) stability and the establishment of Catchment Management Agencies (CMAs). However, it criticizes the draft for lacking specific timeframes and financial details, failing to afford legal status to Catchment Management Forums (CMFs), and omitting necessary reforms for the Water Tribunal. The CER specifically warns that proposed revisions to the 'Reserve' for economic development may complicate its implementation and threaten ecosystems.
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Document type: Statement
SUBMISSIONS REGARDING THE REVIEW OF THE NATIONAL FRAMEWORK FOR AIR QUALITY MANAGEMENT
The Centre for Environmental Rights (CER), representing groundWork, the South Durban Community Environmental Alliance (SDCEA), and the Vaal Environmental Justice Alliance (VEJA), submitted comments on August 22, 2012, regarding the review of the National Framework for Air Quality Management. The submission criticizes the lack of a systematic review of the 2007 Framework, the absence of a current State of the Air Report, and significant gaps in air quality monitoring and public access to information. The CER advocates for more stringent emission standards, mandatory reporting for data holders, and a more inclusive, transparent review process.
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Document type: Statement
Palm Oil Strategy Review Comments
The document critiques the World Bank Group's draft palm oil strategy, highlighting systemic failures in protecting indigenous land rights and biodiversity. It specifically warns against a 'loophole' regarding Financial Intermediaries (FIs) and Advisory Services, which the authors claim could be used to bypass environmental and social safeguards. The authors argue that investment should only occur after a strict sequencing of policy and regulatory capacity building, and they call for the continuation of the sector-wide moratorium on palm oil lending until these issues are resolved.
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Document type: Statement
COMMENTS ON IFC’S CONSULTATION DRAFTS OF THE IFC SUSTAINABILITY POLICY AND PERFORMANCE STANDARDS AND DISCLOSURE POLICY
The document argues that the IFC's shift toward an "outcomes-based" approach has reduced its accountability and oversight, leading to inadequate risk identification and poor development outcomes. It calls for a return to more stringent, verifiable requirements, particularly regarding the rights of indigenous peoples, climate change mitigation, and transparency in financial intermediary lending.
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Document type: Statement
Submission by Civil Society Organizations to the International Finance Corporation Commenting on The Social and Environmental Sustainability Policy, Performance Standards and Disclosure Policy
The document outlines systemic failures in the IFC's environmental and social due diligence, highlighting an overreliance on unverified client data and inadequate project categorization. It calls for the explicit integration of international human rights standards, including the right to free, prior and informed consent for indigenous peoples, and a strategic shift away from fossil fuel investments toward renewable energy. The authors also criticize the 'loophole' created by financial intermediaries and demand greater transparency in extractive industry contracts.
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Document type: Statement
Comments on Draft South African Framework on Article 6
A statement submitted on 13 December 2024 by a coalition of civil society organizations, including Natural Justice and SAFCEI, providing critical comments on South Africa's Draft Article 6 Framework. The coalition argues that carbon markets are fundamentally flawed and risk enabling human rights abuses, land grabs, and the evasion of actual emission reductions.
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Document type: Statement