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The Centre for Environmental Rights (CER) submitted written comments on the Water Services Amendment Bill [B24 – 2025], welcoming the introduction of a licensing regime for Water Services Providers (WSPs) and personal liability for directors and municipal managers. However, the CER raised significant concerns regarding the concentration of authority in the Director General, the lack of mandatory environmental and public-health standards in the licensing process, and the absence of emergency enforcement mechanisms for acute pollution events. The CER argues that while the Bill improves governance, it fails to address systemic under-funding of infrastructure and climate-change resilience.

The Centre for Environmental Rights (CER), representing groundWork and Earthlife Africa, submitted comments on July 23, 2021, regarding the Department of Forestry, Fisheries and the Environment's (DFFE) draft Guideline for considering climate change implications in environmental authorisations and licenses. While welcoming the initiative, the CER argues that the draft is insufficient to address the climate crisis and fails to meet the legal requirements of the Constitution and the National Environment Management Act (NEMA). The submission advocates for a 1.5°C warming limit as the primary benchmark for emissions assessments rather than Nationally Determined Contributions (NDCs), and calls for the inclusion of social costs of carbon and full lifecycle GHG emissions in project evaluations.