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agua para la vida y el sustento
This briefing by Friends of the Earth International, produced for the 3rd World Water Forum in Kyoto, argues that water should be treated as a fundamental human right and a public trust rather than a commodity. It critiques the privatization of water services and the influence of international financial institutions in imposing market-based models on developing nations, advocating instead for sustainable, participatory, and public management that prioritizes basic human needs and ecosystem health.
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Document type: Briefing
International agua con justicia para todos resistencia mundial y local contra el control empresarial y la mercantilización del agua
This report by Friends of the Earth International (FoEI) examines the global trend of water privatization and the role of international financial institutions and corporations in commodifying water resources. It argues that water should be treated as a fundamental human right and a social good rather than a commodity, detailing various local and international resistance movements against corporate control of water.
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Document type: Report
El papel que juega el Banco Europeo de Inversiones en el desarrollo
This 2003 fact sheet by Friends of the Earth International examines the role of the European Investment Bank (EIB) in providing development loans, particularly to Africa, Caribbean, and Pacific (ACP) countries. It argues that while the EIB is a central financial institution for the EU's relations with developing nations, it lacks a formal development strategy and fails to integrate sustainable development or poverty eradication goals into its project evaluations, which remain focused on economic and technical criteria.
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Document type: Fact sheet
Open letter to the President of the World Bank concerning the International Advisory Group
An open letter from civil society representatives in Chad and Cameroon to World Bank President Wolfensohn expressing concerns over the terms of reference for the International Advisory Group (IAG) created to monitor the Chad/Cameroon pipeline project.
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Document type: Statement
Comments on Draft Terms of Reference for the International Advisory Group for the Chad-Cameroon Pipeline
The Center for International Environmental Law and a coalition of NGOs provided comments on the draft Terms of Reference (TOR) for the International Advisory Group (IAG) for the Chad-Cameroon Pipeline. The authors argue that the IAG must have a specific mandate to monitor human rights, possess enforcement authority to suspend loan disbursements if conditions are not met, and maintain a transparent appointment process involving civil society input.
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Document type: Statement
CIEL BRIEF
This briefing by the Center for International Environmental Law (CIEL) critiques the World Bank's proposed transition from Operational Directive (OD 4.30) to Operational Policy (OP 4.12) regarding involuntary resettlement. CIEL argues that the new policy relaxes standards for restoration of living conditions, prioritizes cash over land compensation, and removes protections for vulnerable groups and 'voluntary' settlers.
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Document type: Briefing
Profitably Stabilizing Global Climate
This editorial, published by the Rocky Mountain Institute, argues that stabilizing the global climate is not only possible but profitable through the application of advanced resource efficiency in energy, farming, and forestry. It contends that the costs of climate abatement are often overestimated by econometricians and that market failures, rather than a lack of cost-effective technology, prevent the widespread adoption of these solutions.
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Document type: Statement
Avis d’objection à la décision de réévaluation RDV2017-01 sur le Glyphosate
This document is a formal statement of objection submitted by Louise Vandelac and Marie-Hélène Bacon on behalf of the Canadian Association of Physicians for the Environment. It challenges the decision RDV2017-01 by Health Canada's Pest Management Regulatory Agency (PMRA/ARLA) to renew the registration of glyphosate-based herbicides (GBHs) for approximately 15 years. The authors argue that the scientific basis for the decision is outdated, overly reliant on confidential industry data, and ignores recent independent research regarding human health, food contamination, and environmental impacts.
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Document type: Statement
2014-05-30-fa15-caia-submission-12-2007-38679d22dd4db821.pdf
This December 2007 submission from the Chemicals and Allied Industries Association (CAIA) to the Department of Environmental Affairs and Tourism (DEAT) critiques the proposed minimum emission standards for listed activities. CAIA argues that the standards lack essential technical elements—such as averaging periods and compliance tolerances—and fail to follow the legally binding National Air Quality Framework. The association specifically opposes the adoption of European Union standards without considering the South African context, suggesting World Bank Standards as a more appropriate minimum baseline.
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Document type: Statement
2014-05-30-fa32-caia-submission-08-2009-580ce04bc7792f42.pdf
The Chemical and Allied Industries Association (CAIA) submitted this statement in August 2009 to express concerns regarding a draft Notice on atmospheric emission limits. CAIA argues that the proposed standards are overly stringent, lack a Regulatory Impact Assessment, and deviate from previous working documents. The association advocates for flexible compliance timeframes, the ability to apply for exemptions based on site-specific impact reports, and the adoption of realistic minimum emission standards that consider technical feasibility and overall environmental footprints.
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Document type: Statement
2014-05-30-fa39-sapia-letter-to-dea-30-04-2010-0adb799e383a26a3.pdf
A letter from the South African Petroleum Industry Association (SAPIA) to the Department of Environmental Affairs dated 30 April 2010, expressing concerns over the final 'List of Activities' published under the National Environmental Management: Air Quality Act, 2004. SAPIA argues that the final legislation deviates significantly from the draft version without adequate consultation or explanation, specifically regarding sulphur dioxide limits, timelines for existing refineries, and vapour recovery mandates.
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Document type: Statement
2014-05-30-fa61-revised-busa-submission-32b0a89bc77f0c70.pdf
This document is a revised submission by Business Unity South Africa (BUSA) providing detailed comments and proposed amendments to a draft Notice regarding activities resulting in atmospheric emissions. BUSA argues that the proposed emission limits and compliance timeframes are often technically and financially unfeasible, potentially harming the economic viability of the industrial and mining sectors during a period of manufacturing decline.
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Document type: Statement
ANNEXURE 6 Table 1: Summary of current annual pollutant emission rates, estimated annual average stack concentrations and Eskom’s requested emission limits
This fact sheet provides a detailed table and analysis of current pollutant emission rates (SO2, NOx, and PM10), estimated stack concentrations, and the emission limits requested by Eskom for 13 power stations. The document highlights inconsistencies in Eskom's reported data and argues that Eskom is effectively seeking exemptions from future Minimum Emission Standards (MES).
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Document type: Fact sheet
annexure-a-26333ba73b763b35.pdf
A formal request sent on 29 November 2016 by the Life After Coal Campaign and other environmental organisations to the South African Minister of Energy, seeking an extension for public comment on the Integrated Energy Plan (IEP) and the Integrated Resource Plan (IRP) Update and demanding the release of critical supporting documents.
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Document type: Statement
WHY THERE IS NO SUCH THING AS CLEAN COAL
This document is an executive summary of a report by Dr. Ranajit Sahu, which argues that the concept of "clean coal" is a myth. It specifically analyzes the 2019 Integrated Resource Plan for Electricity (IRP) proposal to add 1500 MW of new coal power generation in South Africa, concluding that such projects will cause significant air pollution and greenhouse gas emissions regardless of the technology used.
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Document type: Executive summary
PUBLIC HEARINGS OF THE PORTFOLIO COMMITTEE ON ENVIRONMENTAL AFFAIRS ON THE CLIMATE CHANGE DISCUSSION DOCUMENT, OUTLINING SOUTH AFRICA’S POSITION TOWARDS THE 21ST SESSION OF THE CONFERENCE OF THE PARTIES (COP21) TO THE UNITED NATIONS FRAMEWORK CONVENTION ON CLIMATE CHANGE (UNFCCC) IN PARIS, FRANCE, IN DECEMBER 2015.
The Centre for Environmental Rights (CER) submitted a statement to the Portfolio Committee on Environmental Affairs in September 2015 regarding South Africa's position for COP21. The CER argues that climate change mitigation is a Constitutional obligation under section 24, and that current state decisions to build new coal-fired power stations directly contradict these legal duties and national climate policies.
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Document type: Statement
GROUNDWORK’S RESPONDING STATEMENT TO KARPOWERSHIP SA (PTY) LTD’S APPEAL AGAINST THE ENVIRONMENTAL AUTHORISATION REFUSAL DECISION (EA NO. 14/12/16/3/3/2/2005): NGQURA
This responding statement, submitted by groundWork, argues against an appeal by Karpowership SA (PTY) Ltd regarding the Department of Forestry, Fisheries and the Environment's (DFFE) June 23, 2021, decision to refuse Environmental Authorisation (EA) for a gas-to-power project at the Port of Ngqura. groundWork contends that the project is neither necessary nor desirable, citing significant environmental risks, inadequate public participation, and the existence of more sustainable energy alternatives.
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Document type: Statement
zo-28-4f6f70490b0133ea.pdf
This research paper examines the legal framework and practical application of environmental authorizations for mining activities in South Africa, specifically focusing on the Mineral and Petroleum Resources Development Act (MPRDA) and the National Environmental Management Act (NEMA). The author argues that the current system of 'environmental authorizations' is often treated as a mere formality rather than a substantive tool for sustainable development, leading to inadequate environmental protection and a failure to properly integrate social and environmental costs into mining operations.
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Document type: Research paper
gef_fundorfolly_1993-6e93a33e034c9216.pdf
This research paper by Donald M. Goldberg of the Center for International Environmental Law examines the structure, funding, and operational challenges of the Global Environmental Facility (GEF) during its three-year pilot phase (1990-1993). The author highlights concerns from non-governmental organizations (NGOs) and developing countries regarding the lack of transparency, democratic governance, and the potential for 'greenwashing' World Bank projects.
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Document type: Research paper
Key Points on Remedy and Responsible Exit
This briefing by the Center for International Environmental Law critiques the February 2023 draft Approach to Remedial Action and Responsible Exit Principles released by the IFC and MIGA. The document argues that these drafts fail to guarantee remedy for communities harmed by projects and do not meet international human rights law standards.
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Document type: Briefing