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The Centre for Environmental Rights (CER), on behalf of Earthlife Africa and groundWork, submitted formal objections on 14 June 2022 to the Integrated Water Use Licence Application (IWULA) for Phase 2A of the Mokolo Crocodile River (West) Water Augmentation Project (MCWAP-2A). The CER argues that the project is an unnecessary inter-basin transfer designed to support coal expansion, which contradicts South Africa's climate commitments and poses severe risks to aquatic ecosystems and local communities.

This document is a formal appeal submitted by the Centre for Environmental Rights on behalf of Earthlife Africa and groundWork to the Minister of Environmental Affairs. The appeal seeks to set aside an Environmental Authorisation granted on 15 March 2019 to the Department of Water and Sanitation for Phase 2A of the Mokolo and Crocodile River (West) Augmentation Project (MCWAP-2A). The appellants argue that the project is unnecessary, environmentally damaging, and based on outdated energy demand assumptions.

The Freshwater Research Centre (FRC) reviewed the MCWAP Phase 2A Draft Environmental Impact Assessment Report (DEIR) and found it inadequate in its assessment of operational phase impacts on rivers and wetlands. Key criticisms include the failure to account for cumulative climate change risks, the lack of consultation with neighbouring states in the Limpopo River Basin, and the use of a risk matrix that does not assess the significance of impacts as required by NEMA. The FRC highlights significant risks regarding the transfer of poor-quality water and invasive species, such as Water Hyacinth, from the donor Crocodile (West) River and Hartbeespoort Dam to the recipient Matlabas and Mokolo River catchments.