Submission on draft notice to amend the NEMA section 24H registration authority regulations
On 31 January 2022 the ELA made submissions to the DFFE on proposed amendments to the NEMA Section 24H Regulations. Our overarching concern is that the proposed amendments have the potential to render the EIA process less inclusive, and that they thus could undermine environmental justice and the fulfillment of the environmental right. You can read our submissions here. The significance of inclusive environmental governance was highlighted during our April 2022 Streaming Club session – a Protect the West Coast film, Ours, Not Mine. A recording of the session is available on our events page.
Submission to the Department of Forestry, Fisheries and the Environment (DFFE) on the Draft Policy Position on the conservation and ecologically sustainable use of elephant, lion, leopard, and rhino
On 29 July 2021 the ELA made submissions to the DFFE on the Draft Policy Position on the conservation and ecologically sustainable use of elephant, lion, leopard and rhino. The submissions, among other things, support a shift away from trade in elephants, ivory, rhinos and their horns at an international level, and a complete ban on trophy hunting. You can read the submissions here: ELA Comments on ELLR Draft Policy Position - 28 July 2021
As we say in the submissions:
“Wildlife is part of the common heritage of all South Africans, both present and future generations, and all South Africans owe duties of custodianship to wildlife. Moreover the Minister holds biodiversity, including wildlife, in public trust for the benefit of all South Africans. A minority who gain profit from exploiting and using our wildlife should not be the loudest voice, but rather the interests of the broader South African public.”
Submission to the Climate Secretariat on South Africa’s proposed updated NDC under the Paris Agreement
On 29 April 2021 the Parliamentary Submissions Sub-Committee of the ELA and Animal Law Reform South Africa made a provisional joint submission to the Climate Secretariat of the Department of Forestry, Fisheries and Environment on the proposed updated National Determined Contribution (NDC) of South Africa under the Paris Agreement. The focus of the submission is that the NDC does not address the mitigation challenges arising from the agricultural and fishing sectors. You can read the joint submission here.
On 30 April 2021 the Parliamentary Submissions Sub-Committee of the ELA made a submission to the City of Cape Town on the Draft City of Cape Town: Informal Trading By-Law.
Among other things the submission addresses environmental injustice and spatial injustice issues arising from the By-Law for informal traders. The submission argues for equitable treatment of informal traders in line with the Constitution of the Republic of South Africa, 1996. The submission is available here.