Intro paragraph:
Lawyers for Human Rights (LHR) welcomes the opportunity to participate in this important policy reform process. The proposed shift towards a more flexible and risk-based EIA system presents a significant development in South Africa’s environmental governance framework, with potential implications for constitutional environmental rights, administrative justice, and sustainable development
While LHR recognizes the need to improve efficiency in environmental authorisation processes, such reforms must not weaken the substantive and procedural protections afforded under Section 24 of the Constitution, the National Environmental Management Act 107 of 1998 (NEMA), and the Promotion of Administrative Justice Act 3 of 2000 (PAJA).
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