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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.

This responding statement, submitted by groundWork to the Department of Forestry, Fisheries and the Environment (DFFE), argues for the dismissal of Karpowership SA (PTY) Ltd’s appeal against the refusal of an Environmental Authorisation (EA) for a gas-to-power project in Richards Bay. groundWork contends that the project is neither necessary nor desirable, citing significant environmental risks, inadequate public participation, and the existence of more cost-effective, renewable energy alternatives.