Submissions on draft policies
2022: Gas Master Plan Basecase Report
On 31 January 2022, the Life After Coal Campaign submitted comments on the Gas Master Plan Basecase Report to the Department of Mineral Resources and Energy.
2022: Draft National Water Resources Strategy 3
On 28 October 2022, the CER submitted comments on the draft National Water Resources Strategy 3 (NWRS-3) published by the Minister of Water and Sanitation on 29 July 2022 in terms of the National Water Act, 1998. In the submission, the CER identified key legal, regulatory and governance matters in the draft NWRS-3 that we believe are crucial to the regulation and management of water.
2021: Draft National Mine Closure Strategy
On 23 July 2021 the Centre for Environmental Rights submitted written comments on the Draft National Mine Closure Strategy 2021.
The submission is available here.
In our comments, we commend and support the Department of Mineral Resources and Energy (DMRE) on its intention to publish the draft national mine closure strategy thereby facilitating increased certainty and best practice in ensuring consideration of all issues relating to mine closure, decommissioning and rehabilitation. We are concerned however that the Strategy’s problem statement does not acknowledge what is considered elsewhere in the strategy around how it is the communities that bear the burden of the various risks emanating from mining. We submit that this is crucial in ensuring community impacts and needs are responded to. While the draft national strategy is welcomed, we urged the DMRE to continuously ensure that regional mine closure strategies are in line with the national strategy, as far as these regional strategies are not yet developed, we urge the DMRE to consider their development to aid in the process of mine closure.
2021: Draft Artisanal and Small Scale Mining Policy
On 17 June 2021, the Centre for Environmental Rights submitted comments on the Draft Artisanal and Small Scale Mining Policy (5 May 2021).
2019: Draft Mine Community Resettlement Guidelines
The Minister of Mineral Resources and Energy published draft Mine Community Resettlement Guidelines on 4 December 2019.
The Centre for Environmental Rights submitted a Letter and Table of Comments on the draft Mine Community Resettlement Guidelines on 31 January 2020.
2017: Draft Mine Water Management Policy Position
The Draft Mine Water Management Policy Position was published by the Department of Water and Sanitation for comment on 7 July 2017. The stated purpose of the policy position is to provide the position of the Department of Water and Sanitation on mine water management, including acid mine drainage and to provide for measures on protection of water resources from prospective, operational and historical mine activities that have negative quality impacts. The Centre for Environmental Rights submitted its comments on the draft policy position on 4 September 2017.