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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 The appellants argue that the project is unnecessary, environmentally damaging, and based on outdated energy demand assumptions.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.

The Centre for Environmental Rights (CER), acting for Earthlife Africa NPC and groundWork, submitted comments on 11 April 2018 regarding the draft Scoping Report for the Mokolo and Crocodile River (West) Water Augmentation Project (Phase 2) (MCWAP-2). The CER argues that the project is based on outdated assumptions regarding South Africa's energy needs and fails to adequately assess climate change, water reserves, and indirect environmental and health impacts.

The analysis concludes that river flows in the Mokolo and Crocodile (West) catchments are very likely to decline due to a combination of projected precipitation decreases and increased evaporation driven by rising temperatures. Using the American Southwest as a semi-arid analog, the author argues that temperature-induced flow declines will occur even if modest precipitation increases happen. The report warns that these systems are already over-allocated and that further warming, potentially reaching 5°C under high-emissions scenarios, will exacerbate water shortages and increase the frequency of 'flash droughts'.

This Climate Resilience Assessment (CRA), conducted by Environmental Resources Management Southern Africa Pty (Ltd) in January 2017, evaluates climate-related risks for the proposed 1,200 MW Thabametsi coal-fired power station in Lephalale, Limpopo Province, South Africa. The report identifies key vulnerabilities related to increasing temperatures, water scarcity, and extreme weather events, proposing adaptation measures to enhance the project's long-term resilience.