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The Role of Public Procurement in Deploying Sustainable Infrastructure
The document argues that sustainable public procurement is essential for deploying infrastructure that optimizes value for money (VfM) across the entire asset life cycle. It details the roles of governments, development banks, and private investors in managing environmental and social risks, and examines the legal instruments—such as UNCITRAL and EU directives—that enable the integration of sustainability into tendering. The paper also discusses the importance of Environmental Impact Assessments (EIAs) and the use of financial incentives like green bonds and accelerated depreciation to encourage green innovation.
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Document type: Research paper
Civil Society Statement, September 22, 2016 Concerns Regarding Green Climate Fund and Support for High Environmental & Social Risk Programs/Projects
More than 100 civil society organizations express deep concern over the Green Climate Fund's (GCF) lack of adequate policies for financing high-risk activities. The statement argues that the GCF Board should not approve high-risk projects—including large hydropower and infrastructure—until it adopts a full Environmental and Social Management System (ESMS) and a free-standing Indigenous Peoples' Policy aligned with international standards like UNDRIP. The groups demand more rigorous scrutiny for high-risk sub-projects, country-driven proposals, and strict adherence to public disclosure timelines for impact assessments.
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Document type: Statement
Oil and Fisheries in Ghana: Prospects for a Socio-ecological Compact
The document examines the intersection of Ghana's oil industry and its artisanal fisheries, which account for 60-70% of the total marine catch. While initial tensions focused on exclusion zones around oil platforms and collisions, the paper argues that the oil sector is not the primary threat to fisheries sustainability. Instead, the sector faces systemic challenges including fleet overcapacity, illegal fishing practices, and climate change. The author advocates for a 'socio-ecological compact' where the oil industry, government, and fishing communities collaborate through integrated maritime governance and co-management to ensure long-term sustainability.
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Document type: Research paper
WRITTEN SUBMISSIONS TO THE SOUTH AFRICAN HUMAN RIGHTS COMMISSION FOR THE NATIONAL INVESTIGATIVE HEARING ON THE UNDERLYING SOCIO-ECONOMIC CHALLENGES IN MINING-AFFECTED COMMUNITIES IN SOUTH AFRICA
The document argues that poor environmental governance by the Department of Mineral Resources (DMR) and the Department of Water and Sanitation (DWS) leads to systemic violations of environmental rights in South Africa's mining sector. It highlights severe impacts on water resources, including acid mine drainage and the depletion of aquifers, and notes the destruction of strategic water source areas (SWSAs). The CER identifies critical failures in the Environmental Impact Assessment (EIA) process, citing insufficient timeframes for public participation and a lack of independence among practitioners. It recommends transferring environmental regulation of mines from the DMR to environmental authorities, implementing free prior and informed consent (FPIC) for communities, and establishing 'no-go' areas for mining in ecologically sensitive zones.
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Document type: Statement
Review of Environmental Impact Assessment Report & Environmental Management Programme, and Environmental Authorisation, for Yzermyn underground coal project
The review concludes that the Yzermyn underground coal project's EIAR and EMPr are of poor quality, failing to address critical concerns from the Department of Environmental Affairs (DEA), Department of Water Affairs (DWA), and Department of Mineral Resources (DMR). The author argues that the project poses high risks to 'irreplaceable' biodiversity and water resources, specifically regarding acid mine drainage and the drawdown of wetlands. The review asserts that the competent authority ignored these risks and the NEMA principles when granting environmental authorisation, focusing only on surface footprint rather than landscape-scale impacts.
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Document type: Report
Review of Environmental Impact Assessment Report & Environmental Management Programme, and Environmental Authorisation, for Yzermyn underground coal project
The review concludes that the Yzermyn underground coal project's EIAR and EMPr are of poor quality, failing to address critical concerns raised by the Department of Environmental Affairs (DEA), Department of Water Affairs (DWA), and Department of Mineral Resources (DMR). Key failures include the lack of updated specialist studies for the 'best environmental option', inadequate assessment of acid mine drainage (AMD) and its long-term decant risks, and a failure to account for cumulative impacts on 'irreplaceable' biodiversity and water resources. The reviewer asserts that the project's focus on surface 'footprint' impacts ignores wider landscape-scale damage to Freshwater Ecosystem Priority Areas (FEPAs) and the Grassland Important Bird Area. Furthermore, the review finds that the Environmental Authorisation was granted despite these deficiencies, relying on misleading information and failing to apply the NEMA principles of sustainable development.
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Document type: Report
NATIONAL INVESTIGATIVE HEARING ON THE UNDERLYING SOCIO-ECONOMIC CHALLENGES IN MINING-AFFECTED COMMUNITIES IN SOUTH AFRICA
The South African Human Rights Commission (SAHRC) is convening a National Hearing on 13-14 September 2016 to investigate socio-economic challenges in mining-affected communities across South Africa. Following consultations in KwaZulu-Natal, Limpopo, and Mpumalanga, the Commission identified systemic issues including non-compliance with legal and environmental obligations, failures in enforcement, insufficient community consultation, and limited social upliftment. The SAHRC has invited the Centre for Environmental Rights to provide submissions specifically regarding the efficacy of environmental compliance monitoring, the implementation of Environmental Impact Assessments (EIAs) and Environmental Management Plans (EMPs), and the impact of mining on water resources and ecosystems.
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Document type: Statement
Review of the groundwater documemtation related to the proposed Yzermyn Colliery
The review identifies significant contradictions and scientific gaps in the groundwater and wetland assessments for the proposed Yzermyn Colliery. It argues that the mine is likely to decant post-closure and that the dewatering process will affect groundwater-dependent ecosystems and springs. The author criticizes the amended EIAR for making scientifically unproven claims about the limited impact on wetlands and the speed of stabilization, while noting that the EcoPartners report on downstream water usage is poorly motivated and fails to quantify key impacts.
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Document type: Report
Review of the groundwater documemtation related to the proposed Yzermyn Colliery
The review identifies significant scientific gaps and contradictions in the groundwater and wetland assessments for the proposed Yzermyn Colliery. Key concerns include the underestimation of drawdown effects on sensitive wetlands, the likelihood of post-closure mine decant with high sulphate levels, and contradictions in wetland sensitivity ratings. The author argues that current models fail to quantify impacts on groundwater-dependent ecosystems and downstream users, recommending further field work and more comprehensive numerical modelling.
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Document type: Report
Review of the groundwater documemtation related to the proposed Yzermyn Colliery
The review identifies significant contradictions and scientific gaps in the groundwater and wetland assessments for the proposed Yzermyn Colliery. It argues that the mine is likely to decant acidic water and that the drawdown of the shallow aquifer will negatively impact groundwater-dependent ecosystems and wetlands, contradicting claims in the amended EIAR that such impacts would be limited or mimic drought conditions.
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Document type: Report
The World Bank Safeguards
The World Bank's Safeguard policy is criticized for devaluing community voices by failing to require that crucial project information be shared with local populations. A survey of civil society actors across 40 countries indicates that 79% of communities learn about projects from partner organizations rather than the Bank. Barriers to information include intermittent internet access, lack of native language translations, and the use of dense technical jargon. The author advocates for guaranteed access to Environmental and Social Impact Assessments, Resettlement Action Plans, and Indigenous Peoples Plans to prevent forced evictions and ecosystem destruction, citing a recent $73.1 million funding withdrawal for a dam in the Democratic Republic of Congo as evidence that the Bank can act when standards are violated.
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Document type: Statement
Investing in Land for Water: The converging legal regimes
The document examines how foreign agricultural investments in Africa exacerbate water stress and the legal tensions between investor rights and the human right to water. It highlights the vulnerability of customary water rights compared to statutory contracts and the potential for investment treaties to limit a state's ability to reallocate water during shortages. The authors recommend integrating international human rights and environmental law into domestic legislation and investment contracts to ensure sustainable water governance.
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Document type: Policy brief
Petition on Barro Blanco: Don't evict Ngäbe families for the Barro Blanco dam
The document is a petition signed by over 105,000 people urging the Panamanian government to stop the forced eviction of approximately 270 Ngäbe indigenous people to make way for the Barro Blanco dam. It highlights that the project threatens to flood six hectares of indigenous territories, including homes, schools, and cultural sites. Despite the concessionary, GENISA, being fined $775,000 in September 2015 for failing to reach agreements with stakeholders, the government has allowed construction to proceed by declaring the project a matter of national interest.
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Document type: Statement
SUBMISSIONS ON THE BACKGROUND INFORMATION DOCUMENT FOR THE PROPOSED MOKOLO CROCODILE (WEST) WATER AUGMENTATION PROJECT PHASE 2
The Centre for Environmental Rights, acting for Earthlife Africa Johannesburg, submitted comments on the Background Information Document (BID) for the proposed Mokolo Crocodile (West) Water Augmentation Project Phase 2 (MCWAP-2). The submission expresses significant reservations regarding the project's sustainability and feasibility, citing climate change and water scarcity, and requests further clarity on the environmental impact assessment (EIA) process and public consultation.
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Document type: Statement
comments-on-proposed-offshore-leasing-program-for-2017-2022
The Institute for Policy Integrity recommends that the agency expand its use of 'option value'—the value of delaying leasing to resolve uncertainties—and incorporate downstream greenhouse gas emissions into its decision-making process for the 2017-2022 offshore leasing program.
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Document type: Statement
RECOMMENDATIONS FOR THE CLIMATE CHANGE IMPACT ASSESSMENT TO BE CONDUCTED BY THABAMETSI POWER PROJECT (PTY) LTD
The Centre for Environmental Rights (CER), on behalf of Earthlife Africa Johannesburg, provides recommendations to improve the scope of the Climate Change Impact Assessment (CCIA) and Palaeontological Impact Assessment Report (PIAR) for the proposed 1200MW Thabametsi coal-fired power station near Lephalale, Limpopo. The CER argues that the current scoping report is too narrow and fails to align with international best practices or South Africa's climate commitments under the Paris Agreement and its Intended Nationally Determined Contribution (INDC).
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Document type: Statement
Recommendations for appeals against decisions of the Executive Board of the Clean Development Mechanism
The document argues that the Clean Development Mechanism (CDM) requires a robust appeals procedure to ensure accountability, human rights protection, and climate integrity. Carbon Market Watch recommends that the scope of appeals cover both positive and negative decisions, be open to a broad definition of affected stakeholders beyond project proponents, and address both procedural and substantive violations. The statement emphasizes that public participation and access to administrative proceedings are essential for verifying that projects result in real greenhouse gas reductions without adverse social or environmental impacts.
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Document type: Statement
Making Sustainable Development the Key Focus of the BRICS New Development Bank
The paper argues that the New Development Bank (NDB) lacks a clear, shared definition of sustainable development and suggests that South Africa could lead the BRICS group in establishing a holistic framework. Drawing on stakeholder interviews and international best practices, the authors recommend that the NDB prioritize social and environmental safeguards, move away from coal and extractive industries, and establish formal dialogue mechanisms with civil society to ensure transparency and pro-poor outcomes.
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Document type: Research paper
Marco de Manejo Ambiental y Social para el proyecto Manejo Integrado Transfronterizo con Enfoque de la Cuenca al Arrecife para el Sistema Arrecifal Mesoamericano
The document provides an Environmental and Social Management Framework (ESMF) for a project aimed at conserving freshwater, marine, and coastal resources in the Mesoamerican Reef System (MAR). It defines the institutional roles of the Central American Commission on Environment and Development (CCAD) and partner NGOs, establishes a project classification system (Categories A, B, and C) based on risk, and outlines procedures for Environmental and Social Impact Assessments (ESIAs). The framework identifies priority river basins—including the Hondo, Motagua, Belice, Chamelecón, and Ulúa—and details the threats facing the reef, such as agricultural runoff, deforestation, and urban waste. It also sets strict safeguards for indigenous peoples, involuntary resettlement, and the use of hazardous pesticides, while proposing various 'ridge-to-reef' interventions like agroforestry and habitat restoration.
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Document type: Report
Stakeholder comments regarding ongoing human rights concerns associated with the Barro Blanco Hydroelectric Power Plant Project (CDM Project #3237)
Stakeholder organizations are urging the CDM Executive Board to intervene in the Barro Blanco Hydroelectric Power Plant Project in Panama due to ongoing human rights concerns, including threats of forced eviction of Ngäbe indigenous communities and failure to obtain free, prior and informed consent. The authors highlight that the project developer, GENISA, was fined $775,200 by Panama's Environment Ministry for non-compliance with its environmental impact assessment, including failures to relocate and compensate affected people. The stakeholders request that the Board notify UN human rights bodies, inquire with Panamanian authorities, and consider withdrawing the project's registration if it violates CDM procedures.
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Document type: Statement