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WRITTEN SUBMISSIONS: WATER SERVICES AMENDMENT BILL [B24 – 2025]
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.
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Document type: Statement
LSM Indonesia dan Wadah Pemikir Internasional Terkait Menyerukan kepada Industri Fashion untuk Mengesampingkan Biomassa demi Memastikan Transisi Energi Bersih dari Bahan Bakar Fosil dan Solusi Pal
An open letter from Indonesian civil society organizations and international think tanks urging global fashion brands to abandon biomass as a fuel source in their supply chains, arguing that it is a 'false solution' that drives deforestation and undermines the transition to truly clean energy like solar and wind.
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Document type: Statement
URGENT REQUEST FOR INFORMATION RELATING TO CLIMATE CHANGE BILL B9-2022
The Centre for Environmental Rights, representing groundWork, Earthlife Africa, and the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted an urgent request for information to the South African Minister of Forestry, Fisheries and the Environment regarding the Climate Change Bill B9-2022. The letter seeks clarification on the removal of emissions trajectories, the status of national adaptation plans, the timeline for regulations, and access to a recent socio-economic impact assessment to enable meaningful public participation before the May 27, 2022, comment deadline.
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Document type: Statement
Item 3: Interactive Dialogue with the Special Rapporteur on the Right to Food
A joint statement by the Center for International Environmental Law and Pesticide Action Network urging the FAO to rescind its partnership with CropLife International due to conflicts of interest and human rights concerns.
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Document type: Statement
COMMENTS ON THE REVISED ATMOSPHERIC IMPACT REPORT AND ATMOSPHERIC EMISSION LICENCE APPLICATION FOR THE PROPOSED IPP THABAMETSI COAL-FIRED POWER STATION
The Centre for Environmental Rights (CER), on behalf of Earthlife Africa and groundWork, submitted comments on September 20, 2018, objecting to the Atmospheric Emission Licence (AEL) application for the proposed Thabametsi coal-fired power station. The CER argues that the project should be refused because it is located in an air quality priority area already in non-compliance with National Ambient Air Quality Standards (NAAQS) and is predicted to cause further non-compliance, specifically regarding sulphur dioxide (SO2). The CER claims the Atmospheric Impact Report (AIR) is fatally flawed due to gross miscalculations of emissions, missing modelling data, and a failure to adequately assess cumulative and health impacts.
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Document type: Statement
Department of Labour's conduct in Parliament undermines meaningful national minimum wage package
The Institute for Economic Justice (IEJ) criticizes the South African Department of Labour for undermining the National Minimum Wage (NMW) package through its conduct in Parliament. The IEJ alleges that the department ignored decisions from the Parliamentary Labour Portfolio Committee and the February 2017 Nedlac agreement, specifically by weakening the independence of the NMW commission, failing to guarantee annual wage increases, and introducing employer-led exemption applications.
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Document type: Statement
Comments on the proposed Implementing Act on Regulation (EU) No 511/2014
This statement, issued by The Berne Declaration and Natural Justice on January 15, 2015, provides critical feedback on the draft Implementing Act for Regulation (EU) No 511/2014, which implements the Nagoya Protocol in the European Union. The authors identify significant gaps in the monitoring of user compliance, particularly when users and commercializers are different entities or operate outside the Union, and express concerns over blanket confidentiality clauses that could shield fraudulent access to genetic resources and traditional knowledge from public scrutiny.
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Document type: Statement
Shambolic, shameful and symbolic
This research paper analyzes the 2014 Protocol on Amendments to the Protocol on the Statute of the African Court of Justice and Human Rights (ACJHPR Amendment), specifically focusing on a provision that grants immunity from prosecution to serving African Union (AU) heads of state and senior officials. The author argues that this immunity provision is a symbolic reaction to the International Criminal Court's (ICC) focus on Africa and is contradictory to the AU's own constitutive principles and other regional agreements.
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Document type: Research paper
Reply to the European Commission’s Public Consultation on Investment Protection and Investor-to-State Dispute Settlement (ISDS) in the Transatlantic Trade and Investment Partnership Agreement (TTIP)
This report by the International Institute for Sustainable Development (IISD) provides a detailed response to the European Commission's 2014 public consultation on investment protection and Investor-to-State Dispute Settlement (ISDS) within the Transatlantic Trade and Investment Partnership Agreement (TTIP). The IISD analyzes proposed text—much of it derived from the EU-Canada Agreement (CETA)—and argues that there are significant inconsistencies between the Commission's stated goals of protecting the right to regulate and the actual legal language proposed, which the IISD suggests could still allow for expansive arbitral interpretations.
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Document type: Report
Friends of the Earth International Position on REDD (Reducing Emissions from Deforestation and forest Degradation)
Friends of the Earth International (FoEI) declares a 'NO REDD' position, opposing all forms of Reducing Emissions from Deforestation and forest Degradation (REDD) schemes, whether market-based or publicly funded. The organization argues that REDD commodifies forests, undermines the rights of Indigenous Peoples and local communities, and fails to address the structural causes of climate change by allowing industrialized nations to avoid direct emissions reductions through the use of carbon offsets.
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Document type: Statement
SUBMISSION OF CENTER FOR INTERNATIONAL ENVIRONMENTAL LAW (CIEL) ON BEHALF OF CIEL, FRIENDS OF THE EARTH, SIERRA CLUB AND CENTER FOR BIOLOGICAL DIVERSITY BEFORE THE U.S. SENATE COMMITTEE ON FINANCE HEARING ON THE TRANSATLANTIC TRADE AND INVESTMENT PARTNERSHIP: ACHIEVING THE POTENTIAL
This statement by the Center for International Environmental Law (CIEL), submitted on behalf of itself, Friends of the Earth, Sierra Club, and Center for Biological Diversity, warns that the Transatlantic Trade and Investment Partnership (TTIP) could undermine public health and environmental protections, particularly regarding toxic chemicals. The document argues that the pursuit of 'regulatory coherence' through harmonization and mutual recognition may lower standards to a 'lowest-common denominator,' preempt sub-national laws, and create chilling effects on the development of safety regulations globally.
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Document type: Statement
Commentary to the Draft Investment Chapter of the Canada-EU Comprehensive Economic and Trade Agreement (CETA)
This report provides a critical commentary on the February 2013 draft Investment Chapter of the Canada-EU Comprehensive Economic and Trade Agreement (CETA). The author argues that the draft largely ignores concerns from the European Parliament and civil society, particularly regarding the inclusion of investor-state dispute settlement (ISDS) and the use of broad, open-ended definitions that may limit the policy space of governments to regulate in the public interest.
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Document type: Report
POSITIVE OR NEGATIVE? Compulsory HIV testing of alleged sexual offenders
This research paper examines the proposed legislation for the compulsory HIV testing of alleged sexual offenders in South Africa, which was incorporated into the Criminal Law (Sexual Offences and Related Matters) Amendment Bill. The author argues that these provisions are redundant for police investigations and lack practical utility for victims due to the HIV 'window period,' thereby constituting an unjustifiable limitation of an accused person's constitutional right to privacy.
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Document type: Research paper
Separate Comments of TEPAC Members on the U.S.-Central American Free Trade Agreement (CAFTA)
A statement by members of the Trade and Environment Policy Advisory Council (TEPAC) expressing concerns that the U.S.-Central American Free Trade Agreement (CAFTA) fails to meet the 'no greater substantive rights' mandate of the Trade Act of 2002 and poses threats to national regulatory powers and environmental protections.
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Document type: Statement
Separate Comments of TEPAC Members on the Investment Chapter of the U.S.- Australia Free Trade Agreement
This document consists of separate comments submitted by four members of the Trade and Environmental Policy Advisory Committee (TEPAC) regarding the investment chapter of the U.S.-Australia Free Trade Agreement (FTA). The authors express approval that the agreement lacks an investor-state dispute mechanism but argue that the substantive investment provisions remain problematic, fail to comply with the Trade Act of 2002's "no greater substantive rights" mandate, and pose threats to environmental regulation and public governance.
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Document type: Statement
extractos del informe borrador de la revisión de las industrias extractivas (rie), versión II
This document contains excerpts from a draft report by Friends of the Earth International (FoEI) reviewing the extractive industries (EI) and the role of the World Bank Group (WBG). It critiques the WBG's structural adjustment policies, its failure to protect indigenous peoples and local communities, and its insufficient approach to climate change and human rights in the context of mining, oil, and gas projects.
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Document type: Report
TREATMENT OF BIODIVERSITY RELATED ISSUES IN THE WTO
This briefing by the Center for International Environmental Law (CIEL) provides preliminary comments on the second drafts of the Ministerial Declaration and Implementation Decision for the Doha Ministerial Conference. The authors argue that these documents fail to adequately integrate the principles and objectives of the Convention on Biological Diversity (CBD) into the WTO framework, particularly within the TRIPS Agreement, and do not sufficiently address the concerns of developing countries regarding sustainable development and genetic resources.
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Document type: Briefing
U.S. Patent and Trademark Office Reinstates Ayahuasca Patent
This briefing by the Center for International Environmental Law (CIEL) criticizes the U.S. Patent and Trademark Office (PTO) for reinstating a plant patent awarded to Loren Miller for a variety of ayahuasca (Banisteriopsis caapi) known as "Da Vine." The author argues that the PTO erred by applying infringement standards rather than patentability standards and by ignoring procedural rules to accommodate the patent holder while excluding indigenous organizations from the reexamination process.
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Document type: Briefing
SUSTAINABLE DEVELOPMENT AND POVERTY ALLEVIATION EXPLORING THE LINKS
This research paper by Anantha Kumar Duraiappah of the International Institute for Sustainable Development (IISD) critiques the last 50 years of poverty alleviation strategies and proposes a new working model based on the principles of sustainable development. The author argues that previous approaches failed because they confused the means of economic growth with the end goal of poverty reduction, and suggests integrating Joseph Stiglitz's stakeholder-based transformation model with a guiding principle of sustainable development to ensure distributive and inter-generational justice.
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Document type: Research paper
DEBT SUSTAINABILITY in the context of African Dependency and Underdevelopment
This research paper, based on a lecture by Opa Kapijimpanga, argues that Africa's recurring debt crises are a structural consequence of its position in the 'periphery' of global capitalism. The author contends that debt sustainability is unattainable under neoliberalism and requires a fundamental 'delinking' from institutions and ideologies that reinforce dependency and underdevelopment.
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Document type: Research paper