{"query_echo":{"q":"","filters":{"organization":["Centre for Environmental Rights"]},"warnings":[]},"total":{"value":1323,"relation":"eq"},"page":6,"page_size":20,"self":"https://climateinsightsdirectory.org/api/v1/search?organization=centre-for-environmental-rights&page=6","next":"https://climateinsightsdirectory.org/api/v1/search?organization=centre-for-environmental-rights&page=7","stability":"beta","ai_marking":{"digital_source_type":{"uri":"http://cv.iptc.org/newscodes/digitalsourcetype/trainedAlgorithmicMedia","name":"Created using Generative AI"},"notice":"Summary and key insights are generated using artificial intelligence."},"results":[{"id":"cer-000587","url":"https://climateinsightsdirectory.org/document/cer-000587","title":"COMMENTS ON PROPOSED AMENDMENTS TO THE SECTION 24H REGISTRATION AUTHORITY REGULATIONS","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":"2022-01-28","source_url":"https://cer.org.za/wp-content/uploads/2022/02/CER-Comments-on-proposed-changes-to-EAPASA-Regulations-28-January-2022.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights"],"summary":{"text":"The Centre for Environmental Rights (CER) submitted comments to the Department of Forestry, Fisheries and the Environment regarding proposed amendments to the Section 24H Registration Authority Regulations (EAPASA Regulations). The CER objects to further delays in the mandatory registration of environmental assessment practitioners (EAPs) and requests clarification to ensure that the amendments do not restrict the public's right to lodge internal appeals under section 43 of the National Environmental Management Act (NEMA).","ai_generated":true,"unit":"cer-000587#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The Centre for Environmental Rights (CER) strongly objects to a proposed six-month extension for environmental assessment practitioners (EAPs) to register with the Environmental Assessment Practitioners Association of South Africa (EAPASA). The CER notes that the original regulations were published in July 2016, and with the proposed change, industry professionals would have had over six years to register.","ai_generated":true,"unit":"cer-000587#insight-1","date_modified":"2026-08-17"},{"text":"The CER argues that the lack of a legal duty for EAPs to register with EAPASA prevents the body from exercising oversight in an industry that requires regulation. To illustrate this need, the CER cites a 2021 recommendation by the Green Scorpions for criminal charges against an EAP for misleading the Department of Forestry, Fisheries and the Environment, and an appeal involving Buchuberg Resources where an EAP was accused of plagiarism and lacking the proper accreditation to sign off on reports.","ai_generated":true,"unit":"cer-000587#insight-2","date_modified":"2026-08-17"},{"text":"The CER requests that the Department clarify whether the proposed amendments to Regulation 6 and Regulation 14(1)(f) restrict the ability of interested and affected parties (I&APs) to lodge internal appeals under section 43 of NEMA. While the CER does not believe the amendment intends to restrict appeals to only registered EAPs, it warns that such a restriction would unlawfully curtail the ability to challenge environmental authorisations.","ai_generated":true,"unit":"cer-000587#insight-3","date_modified":"2026-08-17"}],"climate_tags":[],"geography_discussed":[],"frame_perspective":[],"analysis_type":[]},{"id":"cer-001231","url":"https://climateinsightsdirectory.org/document/cer-001231","title":"An Open Letter to The South African President Cyril Ramaphosa Minister Gwede Mantashe - Minister of Mineral Resources and Energy, and Minister Barbara Creecy - Minister of Forestry, Fisheries and the Environment Regarding seismic surveys off the South African coastline","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":"2021-12-02","source_url":"https://cer.org.za/wp-content/uploads/2021/12/open-letter-sa-marine-experts-final-2-dec-2021.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"The document argues that offshore seismic surveying is fundamentally damaging to marine ecosystems and contradicts South Africa's COP26 commitments to transition from hydrocarbons to renewables. The authors highlight legal deficiencies in the National Environmental Management Act (NEMA) that allow these surveys to bypass full environmental impact assessments and criticize the outdated Environmental Management Programme (EMPr) used for Shell Oil's surveys off the Transkei Coast. They call for a halt to all planned surveys, a review of EIA regulations, and the commissioning of a Strategic Environmental Assessment for the South African Exclusive Economic Zone.","ai_generated":true,"unit":"cer-001231#summary","date_modified":"2026-10-23"},"key_insights":[{"text":"Offshore seismic surveying uses high-amplitude, low-frequency air gun pulses that cause immediate and long-term negative impacts on marine life, ranging from plankton to whales and dolphins, and threatens sustainable blue economies.","ai_generated":true,"unit":"cer-001231#insight-1","date_modified":"2026-10-23"},{"text":"The Environmental Management Programme (EMPr) used to permit Shell Oil's surveying off the Transkei Coast is considered invalid because it was completed in June 2013 and fails to incorporate recent scientific evidence or independent social and ecological impact audits.","ai_generated":true,"unit":"cer-001231#insight-2","date_modified":"2026-10-23"},{"text":"Current South African legislation under the National Environmental Management Act (NEMA) contains a deficiency that permits speculative seismic surveys to avoid full environmental impact assessment (EIA) processes.","ai_generated":true,"unit":"cer-001231#insight-3","date_modified":"2026-10-23"}],"climate_tags":["blue economy","environmental impact assessment","renewable energy","2021 United Nations Climate Change Conference"],"geography_discussed":["Transkei Coast"],"frame_perspective":[],"analysis_type":["policy critique","scientific advocacy"]},{"id":"cer-001546","url":"https://climateinsightsdirectory.org/document/cer-001546","title":"Assessment of new coal generation capacity targets in South Africa’s 2019 Integrated Resource Plan for Electricity","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"report","language":"en","date_published":"2021-11-01","source_url":"https://cer.org.za/wp-content/uploads/2021/11/ESRG_New-coal-plants-South-Africa_021121.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"The report finds that new coal capacity in the IRP 2019 is unnecessary for energy security, more expensive than renewable alternatives, and incompatible with the Paris Agreement. Modelling shows that forcing 1.5 GW of new coal into the system increases total discounted power system costs by R23 billion in a reference scenario and up to R109 billion in a climate policy scenario. Furthermore, the study argues that a high-renewable pathway creates more jobs and supports higher GDP growth than a coal-dominated future.","ai_generated":true,"unit":"cer-001546#summary","date_modified":"2026-10-23"},"key_insights":[{"text":"A least-cost electricity build plan for South Africa would not include any new investments in coal power.","ai_generated":true,"unit":"cer-001546#insight-1","date_modified":"2026-10-23"},{"text":"In a reference scenario reflecting current economic reality, forcing 1.5 GW of new coal into the power system increases total discounted costs by R23 billion and raises the average unit cost of electricity by 0.8 c/kWh (approximately 0.5%).","ai_generated":true,"unit":"cer-001546#insight-2","date_modified":"2026-10-23"}],"climate_tags":["coal-fired power station","renewable energy","greenhouse gas emissions","Paris Agreement","Nationally Determined Contributions","energy security","just transition","carbon capture and storage","electricity price","employment"],"geography_discussed":["World","United States","European Union","Australia","Germany","Poland","Czech Republic","Vietnam","Pakistan","People's Republic of China","Mexico","Indonesia","Colombia","Argentina","United Kingdom","Denmark","Ireland","Brazil","Turkey","Japan"],"frame_perspective":[],"analysis_type":["economic modelling","policy assessment","comparative analysis"]},{"id":"cer-000043","url":"https://climateinsightsdirectory.org/document/cer-000043","title":"South Africa must walk the talk at COP26","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":"2021-10-13","source_url":"https://cer.org.za/news/statement-south-africa-must-walk-the-talk-at-cop26","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"The Life After Coal campaign calls for South Africa to adhere to the lower bound of its updated NDC (350 to 420 Mt CO2eq) to align with the 1.5°C pathway. This requires cancelling all new coal and gas projects, accelerating the retirement of the coal fleet to reach zero fossil fuels in electricity by 2040, and building at least 4 GW of renewable capacity annually. The campaign also advocates for a just transition that prioritizes workers and communities and urges South Africa to lead at COP26 in demanding increased finance for adaptation and loss and damage from wealthy nations.","ai_generated":true,"unit":"cer-000043#summary","date_modified":"2026-10-23"},"key_insights":[{"text":"To align with the 1.5°C pathway, South Africa must meet the lower bound of its updated Nationally Determined Contribution (NDC) target range, which is between 350 and 420 Mt CO2eq.","ai_generated":true,"unit":"cer-000043#insight-1","date_modified":"2026-10-23"},{"text":"Urgent actions required to meet climate targets include cancelling all new coal projects—specifically the 1500MW in the 2019 Integrated Resource Plan (IRP) and proposed plants in the Musina Makhado Special Economic Zone (MMSEZ)—and avoiding new gas infrastructure, noting that 25,000MW of gas-fired power projects have already seen license or authorization applications.","ai_generated":true,"unit":"cer-000043#insight-2","date_modified":"2026-10-23"},{"text":"The Life After Coal campaign advocates for a total phase-out of fossil fuels in electricity generation by 2040 and a completely fossil-fuel-free economy by 2050, requiring a faster retirement of the coal fleet than the 2019 IRP timetable.","ai_generated":true,"unit":"cer-000043#insight-3","date_modified":"2026-10-23"},{"text":"South Africa needs to build at least 4 GW of wind and solar capacity every year for the remainder of the decade to achieve its committed emission reduction targets, as current progress lags behind the 2019 IRP.","ai_generated":true,"unit":"cer-000043#insight-4","date_modified":"2026-10-23"},{"text":"At COP26, South Africa is urged to demand a scale-up of climate finance for low- and middle-income (LMIC) countries, specifically prioritizing a Global Goal on Adaptation and funding for loss and damage, noting that adaptation currently receives only 25% of total climate finance from developed to developing countries.","ai_generated":true,"unit":"cer-000043#insight-5","date_modified":"2026-10-23"}],"climate_tags":["Nationally Determined Contributions","Coal phase-out","renewable energy","just transition","climate finance","climate change adaptation","loss and damage","natural gas","greenhouse gas emissions","wind power","solar energy"],"geography_discussed":["United States","Australia","India","People's Republic of China","European Union"],"frame_perspective":[],"analysis_type":["policy advocacy"]},{"id":"cer-000786","url":"https://climateinsightsdirectory.org/document/cer-000786","title":"Parliamentary legislative process, timeframes and role-players for the National Climate Change Bill","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"briefing","language":"en","date_published":"2021-10-11","source_url":"https://cer.org.za/wp-content/uploads/2022/03/Climate-Change-Bill-Memo-on-process-11-Oct-2021-Dani.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"This briefing memorandum, written by Danjelle Midgley of the Centre for Environmental Rights (CER), outlines the legislative process, key role-players, and estimated timeframes for the National Climate Change Bill following its introduction to the South African Parliament on 11 October 2021.","ai_generated":true,"unit":"cer-000786#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The National Climate Change Bill is classified as a section 76 bill because it affects the provinces. It was officially introduced in Parliament by Minister Barbara Creecy on 11 October 2021.","ai_generated":true,"unit":"cer-000786#insight-1","date_modified":"2026-08-17"},{"text":"The legislative process involves a sequence starting with the National Assembly's Portfolio Committee on Forestry, Fisheries and the Environment, followed by the National Council of Provinces (NCOP) and its Select Committee on Land Reform, Environment, Mineral Resources and Energy. The bill must then be considered by each of the nine provincial legislatures before returning to the NCOP for negotiation and potential referral back to the National Assembly or a Mediation Committee.","ai_generated":true,"unit":"cer-000786#insight-2","date_modified":"2026-08-17"},{"text":"Key role-players include members of the National Assembly's Portfolio Committee, the NCOP's Select Committee, and environmental committees within the nine provincial legislatures. Political parties are significant influencers, as committee members typically vote according to pre-determined party lines. While the executive no longer controls the bill's content, the Climate Change directorate within the Department of Forestry, Fisheries and Environment remains vital for future implementation and the drafting of Regulations.","ai_generated":true,"unit":"cer-000786#insight-3","date_modified":"2026-08-17"},{"text":"Formal engagement opportunities for the CER include submitting written comments and making verbal presentations to the Portfolio Committee, the Select Committee, and through public participation processes in provincial legislatures. Informal engagement may involve requesting presentations through committee secretaries and chairpersons or engaging individual committee members prior to briefings.","ai_generated":true,"unit":"cer-000786#insight-4","date_modified":"2026-08-17"},{"text":"Based on Parliamentary Monitoring Group (PMG) data from 2006 to 2018, 76% of bills affecting provinces were successfully adopted. On average, it takes 201 days from introduction to adoption, or 73 parliamentary days (approximately 55% of a year).","ai_generated":true,"unit":"cer-000786#insight-5","date_modified":"2026-08-17"},{"text":"The author estimates that the entire process from introduction to adoption will likely exceed 12 months. This is due to the bill's complexity, the late introduction in an election year, and the busy schedules of committees, including the impact of COP26 in early November 2021. Public participation by the portfolio committee is expected to commence in December 2021 or 2022, with verbal presentations likely occurring after February 2022.","ai_generated":true,"unit":"cer-000786#insight-6","date_modified":"2026-08-17"},{"text":"The NCOP's select committee operates on a six-week cycle for section 76 legislation. This process requires the Select Committee to meet with departments and for permanent delegates to brief their provinces. Adoption by the NCOP requires support from five out of nine provinces.","ai_generated":true,"unit":"cer-000786#insight-7","date_modified":"2026-08-17"}],"climate_tags":["climate change bill","legislative process","public participation","south africa","energy transition"],"geography_discussed":["Gauteng","Limpopo","Western Cape"],"frame_perspective":[],"analysis_type":["Policy Analysis","Procedural Briefing"]},{"id":"cer-000575","url":"https://climateinsightsdirectory.org/document/cer-000575","title":"COMMENTS ON THE PROPOSED REGULATIONS PERTAINING TO FINANCIAL PROVISION FOR THE MITIGATION AND REHABILITATION OF ENVIRONMENTAL DAMAGE CAUSED BY RECONNAISSANCE, PROSPECTING, EXPLORATION OR PRODUCTION OPERATIONS, 2021","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":"2021-10-06","source_url":"https://cer.org.za/wp-content/uploads/2021/10/CER-and-Others-Financial-Provisioning-Comments-6-October-2021.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"The document argues that the draft regulations fail to sufficiently protect the state and affected communities from the costs of mine abandonment. It calls for a shift from 'agreed' to 'approved' closure objectives, the inclusion of 'sustainable end use' to address socio-economic inequality and land reform, and the removal of high-risk financial vehicles like parent company guarantees. It specifically highlights regulatory gaps in tailings reprocessing and the environmental risks of seismic surveys in the oil and gas sector.","ai_generated":true,"unit":"cer-000575#summary","date_modified":"2026-10-23"},"key_insights":[{"text":"The signatories argue that closure objectives and the sustainable end state should be approved by the regulator rather than 'agreed' between the applicant and the regulator, to ensure enforceable obligations following public participation.","ai_generated":true,"unit":"cer-000575#insight-1","date_modified":"2026-10-23"},{"text":"The document advocates for replacing 'sustainable end state' with 'sustainable end use' to prioritise land reform, livelihoods, and the rights of women and marginalised groups, noting that mining often aggravates poverty and inequality.","ai_generated":true,"unit":"cer-000575#insight-2","date_modified":"2026-10-23"},{"text":"There is a significant regulatory gap regarding the financial provision for environmental rehabilitation during business rescue and liquidation, as seen in the case of Mintails Mining SA (Pty) Ltd, where a shortfall of R460-million was identified.","ai_generated":true,"unit":"cer-000575#insight-3","date_modified":"2026-10-23"},{"text":"The submission identifies a legal anomaly where the reprocessing of tailings dumps may not be subject to the Mineral and Petroleum Resources Development Act (MPRDA) and thus may bypass the proposed financial regulations.","ai_generated":true,"unit":"cer-000575#insight-4","date_modified":"2026-10-23"},{"text":"The organisations strongly oppose the use of parent or affiliate company guarantees, particularly in the oil and gas sector, arguing they are high-risk 'self-insurance mechanisms' that lack adequate monitoring and control.","ai_generated":true,"unit":"cer-000575#insight-5","date_modified":"2026-10-23"},{"text":"The document warns that seismic surveys in the oil and gas industry cause significant noise pollution that can lead to behavioral changes, habitat abandonment, and mortality in marine mammals and fish, yet are excluded from the draft regulations.","ai_generated":true,"unit":"cer-000575#insight-6","date_modified":"2026-10-23"},{"text":"The signatories propose changing the frequency of financial provision reviews from annual to triennial (every three years) to avoid an impractical and potentially ineffective cycle of constant reassessment.","ai_generated":true,"unit":"cer-000575#insight-7","date_modified":"2026-10-23"},{"text":"The submission criticises the 'low risk commodity' list, arguing that risk is determined by factors such as depth and location rather than just mineral type; for example, sand mining can cause devastating river bed destruction.","ai_generated":true,"unit":"cer-000575#insight-8","date_modified":"2026-10-23"},{"text":"The document highlights a 'pass-the-parcel' approach where mining companies sell sites near closure to under-resourced entities to avoid rehabilitation liabilities, urging the regulator to close these gaps.","ai_generated":true,"unit":"cer-000575#insight-9","date_modified":"2026-10-23"}],"climate_tags":["just transition"],"geography_discussed":["Witwatersrand","Mpumalanga"],"frame_perspective":[],"analysis_type":["policy analysis","legal commentary"]},{"id":"cer-000696","url":"https://climateinsightsdirectory.org/document/cer-000696","title":"REQUEST FOR REASONS: NERSA ELECTRICITY GENERATION LICENCE FOR KARPOWERSHIP RICHARD’S BAY, NGQURA AND SALDANHA","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":"2021-09-22","source_url":"https://cer.org.za/wp-content/uploads/2021/09/CER-letter-to-NERSA-re-Karpowership-and-request-for-reasons-22.09.2021.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights"],"summary":{"text":"The Centre for Environmental Rights, representing groundWork, has requested that the National Energy Regulator SA (NERSA) release the approval documents, reasons, charge rates, and power purchase agreements related to the electricity generation licences granted on 21 September 2021 for Karpowership projects in Richard's Bay, Ngqura, and Saldanha.","ai_generated":true,"unit":"cer-000696#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"On 21 September 2021, the National Energy Regulator SA (NERSA) granted electricity generation licences for three Karpowership projects. During this meeting, NERSA adopted several documents for approval, including the generation licence approvals, the reasons for the decision to grant the licences, charge rates, power purchase agreements, and a two-page summary of these items.","ai_generated":true,"unit":"cer-000696#insight-1","date_modified":"2026-08-17"},{"text":"The Centre for Environmental Rights (CER), representing groundWork (an objector to the licence applications), has requested that NERSA provide the aforementioned approval documents for all three Karpowership projects to them and the public by 30 September 2021.","ai_generated":true,"unit":"cer-000696#insight-2","date_modified":"2026-08-17"}],"climate_tags":[],"geography_discussed":[],"frame_perspective":[],"analysis_type":[]},{"id":"cer-000621","url":"https://climateinsightsdirectory.org/document/cer-000621","title":"LETTER OF DEMAND - INTEGRATED RESOURCE PLAN FOR ELECTRICITY 2019 AND THE MINISTERIAL DETERMINATION ON THE PROCUREMENT OF 1 500 MW OF NEW GENERATION CAPACITY FROM COAL","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":"2021-09-17","source_url":"https://cer.org.za/wp-content/uploads/2021/09/CER-Letter-of-Demand-to-Minister-Mantashe-and-NERSA-2021.09.17.docx.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed"],"summary":{"text":"The Centre for Environmental Rights (CER), acting for groundWork, Vukani Environmental Justice Movement in Action, and the African Climate Alliance, issued a letter of demand to the Minister of Mineral Resources and Energy and the National Energy Regulator of South Africa (NERSA). The letter demands the abandonment of the procurement of 1,500 MW of new coal-generation capacity as specified in the Integrated Resource Plan for Electricity 2019 (IRP 2019) and a September 2020 ministerial determination, citing economic, environmental, and climate risks.","ai_generated":true,"unit":"cer-000621#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The Energy Systems Research Group (ESRG) report indicates that an optimal, least-cost electricity plan would exclude new coal investments. Forcing 1,500 MW of new coal into the build plan would increase electricity prices by 0.5% and incur additional costs of at least R23 billion in a reference scenario. In a climate policy scenario, it would result in additional costs of R109 billion in the power sector.","ai_generated":true,"unit":"cer-000621#insight-1","date_modified":"2026-08-17"},{"text":"The ESRG report finds that new coal capacity would have negative economic and environmental impacts, including a reduction in GDP growth by 0.11% in 2030 and 0.08% in 2040, and the loss of approximately 25,000 jobs in 2030. Additionally, it would increase cumulative greenhouse gas emissions to 2050 by 289 Mt CO2-eq compared to an optimal plan without new coal.","ai_generated":true,"unit":"cer-000621#insight-2","date_modified":"2026-08-17"},{"text":"A report by Dr Ranajit Sahu concludes that high-efficiency, low emission (HELE) technologies cannot adequately mitigate the environmental and climate impacts of new coal. The report asserts that 'clean coal' does not exist and that even with HELE technologies, air emissions remain considerable. It notes that advanced ultra-supercritical (AUSC) plants do not meet the IRP 2019 requirement of having at least one operational project experience.","ai_generated":true,"unit":"cer-000621#insight-3","date_modified":"2026-08-17"},{"text":"The Sahu report highlights specific technical risks: Circulating fluidised bed (CFB) technology, preferred by the IRP 2019 for handling low-quality coal, is associated with very high nitrous oxide (N2O) emissions. Furthermore, carbon capture (CC), integrated gasification combined cycle (IGCC), and underground gasification combined cycle (UGCC) technologies are described as unproven and cost-prohibitive at scale.","ai_generated":true,"unit":"cer-000621#insight-4","date_modified":"2026-08-17"},{"text":"The IPCC AR6 report emphasizes that human influence has unequivocally warmed the planet and that global warming of 1.5°C and 2°C will be exceeded this century without deep emission reductions. For Southern Africa, the IPCC projects increased hot extremes, heavy precipitation, agricultural and ecological drought, fire weather conditions, tropical cyclones, and sea level rises.","ai_generated":true,"unit":"cer-000621#insight-5","date_modified":"2026-08-17"},{"text":"The energy sector is the largest contributor to South Africa's greenhouse gas emissions, accounting for 80.1% of the total, with the combustion of fossil fuels being the primary source.","ai_generated":true,"unit":"cer-000621#insight-6","date_modified":"2026-08-17"}],"climate_tags":["energy transition","coal power","greenhouse gas emissions","integrated resource plan","climate change mitigation"],"geography_discussed":["Southern Africa"],"frame_perspective":[],"analysis_type":[]},{"id":"cer-000787","url":"https://climateinsightsdirectory.org/document/cer-000787","title":"Climate impacts in southern Africa during the 21st Century","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"report","language":"en","date_published":"2021-09","source_url":"https://cer.org.za/wp-content/uploads/2021/09/Climate-impacts-in-South-Africa_Final_September_2021.FINAL_.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"The report identifies southern Africa as a climate change 'hotspot' where warming in the interior is occurring at approximately twice the global average rate. It warns that global warming of 3 °C could lead to the collapse of key crops and the livestock sector. Freshwater availability is projected to decline due to reduced rainfall and increased evaporation, while the risk of multi-year droughts and intense heat waves is expected to rise. These changes threaten food security, increase human mortality in urban areas, and place thousands of unique species at risk of premature extinction. The document emphasizes that the severity of these impacts depends on global mitigation efforts, with 'low mitigation futures' posing significantly higher risks than those limiting warming to 1.5 °C or 2 °C.","ai_generated":true,"unit":"cer-000787#summary","date_modified":"2026-10-23"},"key_insights":[{"text":"Southern Africa is considered a climate change 'hotspot' because its subtropical climate is projected to become drastically warmer and likely drier, with interior warming occurring at about twice the global average rate.","ai_generated":true,"unit":"cer-000787#insight-1","date_modified":"2026-10-23"},{"text":"Agricultural production, specifically staple crops like maize and the livestock sector, faces a high likelihood of reduction and potential collapse if global warming reaches 3 °C.","ai_generated":true,"unit":"cer-000787#insight-2","date_modified":"2026-10-23"},{"text":"Freshwater resources are critically limited and will further decrease due to lower rainfall and higher evaporation; in semi-arid areas of South Africa, the hydrological system amplifies climate signals approximately three-fold.","ai_generated":true,"unit":"cer-000787#insight-3","date_modified":"2026-10-23"},{"text":"The risk of long-duration and multi-year droughts is increasing; for example, the risk of such droughts in the winter rainfall region has already increased by a factor of three due to climate change.","ai_generated":true,"unit":"cer-000787#insight-4","date_modified":"2026-10-23"},{"text":"Heat waves will increase in number, intensity, and duration, leading to higher human mortality—particularly for those over 65—and a reduction in outdoor work capacity by approximately half if global warming exceeds 2 °C.","ai_generated":true,"unit":"cer-000787#insight-5","date_modified":"2026-10-23"},{"text":"There is an increased risk of severe storms and intense tropical cyclones in the southwest Indian Ocean, which cause significant loss of life and infrastructure damage, as evidenced by Cyclone Idai in 2019.","ai_generated":true,"unit":"cer-000787#insight-6","date_modified":"2026-10-23"},{"text":"Biodiversity is under severe threat, with 14% of plants, 17% of mammals, and 15% of birds in South Africa already classified as threatened with extinction, a risk that rises steeply with rapid anthropogenic climate change.","ai_generated":true,"unit":"cer-000787#insight-7","date_modified":"2026-10-23"}],"climate_tags":["greenhouse gas emissions","sea level rise","extreme weather event","heat wave","drought","agricultural production","food security","tropical cyclone","biodiversity loss","climate change mitigation","climate change adaptation","Paris Agreement"],"geography_discussed":["Cape Town","Durban","Johannesburg","Gauteng","Northwest province","Limpopo","Indian Ocean"],"frame_perspective":[],"analysis_type":["impact assessment","risk analysis","projection"]},{"id":"cer-000329","url":"https://climateinsightsdirectory.org/document/cer-000329","title":"The South African Risk Mitigation Power Producers Procurement Programme (RM4P): A techno-economic evaluation of the underlying design of the request for proposals (RFP) and the resultant impact on the outcomes of the RM4P","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"report","language":"en","date_published":"2021-08-27","source_url":"https://cer.org.za/wp-content/uploads/2022/12/Annex-A-Mallinson-Report.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"The report argues that the RM4P procurement process was designed for gas projects, imposing restrictions that increased renewable energy bid tariffs by over 50% and made gas-dominated projects appear erroneously cost-competitive. Modelling suggests that a technology-agnostic, system-integrated approach could halve tariffs, saving Eskom R8 billion annually (R160 billion over the PPA term) while eliminating the 4 million tonnes of annual CO2 emissions produced by the current preferred bidders, 90% of which come from three Karpowership projects.","ai_generated":true,"unit":"cer-000329#summary","date_modified":"2026-10-23"},"key_insights":[{"text":"The RM4P request for proposals (RFP) contained rules and restrictions that disproportionately increased bid tariffs for renewable-dominated projects (solar PV, wind, and energy storage systems) by more than 50%, while having little to no impact on gas-dominated projects.","ai_generated":true,"unit":"cer-000329#insight-1","date_modified":"2026-10-23"},{"text":"Modelling indicates that realigning the RFP to be technology-agnostic and integrating it with existing grid and storage assets could reduce tariffs to R0.72/kWh, potentially saving Eskom and consumers R8 billion per year, or R160 billion over the term of the power purchase agreements.","ai_generated":true,"unit":"cer-000329#insight-2","date_modified":"2026-10-23"},{"text":"The current preferred bidders are projected to produce over four million tonnes of CO2 emissions annually, with the three Karpowership projects accounting for 90% of this total.","ai_generated":true,"unit":"cer-000329#insight-3","date_modified":"2026-10-23"},{"text":"Specific RFP rules, such as the prohibition of charging energy storage systems from the grid at night and the 'Mingen' (minimum generation) rules, significantly penalise renewable projects by forcing the oversizing of storage and requiring the curtailment of output.","ai_generated":true,"unit":"cer-000329#insight-4","date_modified":"2026-10-23"},{"text":"The RM4P's minimum annual contracted capacity rule requires a 50% capacity factor, which is atypical for the open cycle gas turbines or reciprocating gas engines used by the Karpowership projects, which normally operate at no more than 10%.","ai_generated":true,"unit":"cer-000329#insight-5","date_modified":"2026-10-23"},{"text":"The procurement process exposes Eskom to significant financial risks because fuel costs for gas-based projects are treated as pass-through costs, leaving the buyer vulnerable to global LNG price volatility and US dollar exchange rate fluctuations.","ai_generated":true,"unit":"cer-000329#insight-6","date_modified":"2026-10-23"}],"climate_tags":["energy transition","renewable energy","photovoltaics","wind power","natural gas","greenhouse gas emissions","carbon dioxide emissions","power purchase agreement","climate finance","wide area synchronous grid","energy independence"],"geography_discussed":["Richards Bay","Coega","Saldana Bay"],"frame_perspective":[],"analysis_type":["techno-economic evaluation","policy analysis","modelling"]},{"id":"cer-001496","url":"https://climateinsightsdirectory.org/document/cer-001496","title":"Assessment of new coal generation capacity targets in South Africa’s 2019 Integrated Resource Plan for Electricity","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"research paper","language":"en","date_published":"2021-08-27","source_url":"https://cer.org.za/wp-content/uploads/2021/09/Annexure-A_ESRG_New-coal-plants-South-Africa.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"The study finds that new coal generation is unnecessary for energy security, more expensive than renewable alternatives, and incompatible with the Paris Agreement. Modelling shows that forcing 1.5 GW of new coal into the power system increases total discounted costs by R23 billion in a reference scenario and R109 billion in a climate policy scenario, while reducing GDP and employment.","ai_generated":true,"unit":"cer-001496#summary","date_modified":"2026-10-23"},"key_insights":[{"text":"A least-cost electricity build plan for South Africa would not include any new investments in coal power.","ai_generated":true,"unit":"cer-001496#insight-1","date_modified":"2026-10-23"},{"text":"In a reference scenario reflecting current economic reality, forcing 1.5 GW of new coal into the build plan increases total discounted electricity system costs by at least R23 billion and raises the average unit cost of electricity by 0.5% (0.8 c/kWh).","ai_generated":true,"unit":"cer-001496#insight-2","date_modified":"2026-10-23"},{"text":"The inclusion of new coal capacity in the reference scenario increases cumulative national greenhouse gas emissions by 289 Mt CO2-eq by 2050 compared to an optimal plan without new coal.","ai_generated":true,"unit":"cer-001496#insight-3","date_modified":"2026-10-23"},{"text":"Forcing new coal into a climate policy scenario—where emissions are capped to align with the Paris Agreement—increases total discounted power sector costs by R109 billion, raising unit costs by 3.5% (8.0 c/kWh).","ai_generated":true,"unit":"cer-001496#insight-4","date_modified":"2026-10-23"},{"text":"New coal capacity negatively impacts the economy, reducing GDP growth by 0.11% in 2030 and 0.08% in 2040, and resulting in approximately 25,000 job losses in 2030 across the economy.","ai_generated":true,"unit":"cer-001496#insight-5","date_modified":"2026-10-23"},{"text":"Renewable energy creates more jobs per unit of electricity produced than coal, and a high-renewable system generates the highest overall employment across the economy.","ai_generated":true,"unit":"cer-001496#insight-6","date_modified":"2026-10-23"},{"text":"The concept of 'baseload' power is outdated; modern power systems can maintain reliability using a complementary mix of variable renewable energy and flexible dispatchable generators.","ai_generated":true,"unit":"cer-001496#insight-7","date_modified":"2026-10-23"},{"text":"New coal plants are incompatible with the Paris Agreement goals of limiting warming to 1.5°C or well below 2°C, as they would either become stranded assets or force the earlier retirement of existing coal plants to stay within carbon budgets.","ai_generated":true,"unit":"cer-001496#insight-8","date_modified":"2026-10-23"}],"climate_tags":["coal power","renewable energy","greenhouse gas emissions","Paris Agreement","energy security","just transition","employment","climate finance","Nationally Determined Contributions","carbon budget"],"geography_discussed":["United States","European Union","Australia","Germany","Poland","Czech Republic","Vietnam","India","People's Republic of China","United Kingdom","Mexico","Denmark","Ireland","Brazil","Turkey","Japan"],"frame_perspective":[],"analysis_type":["economic modelling","policy assessment","environmental impact analysis"]},{"id":"cer-000393","url":"https://climateinsightsdirectory.org/document/cer-000393","title":"Climate Change Implications for SA’s Youth","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"report","language":"en","date_published":"2021-08-26","source_url":"https://cer.org.za/wp-content/uploads/2022/06/Annexure-A-Nick-King-Report-Final.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"The report warns that South Africa is on a 'worst-case' climate trajectory (RCP 8.5), which will lead to extreme heat, water scarcity, and food insecurity, disproportionately harming youth. It details regional collapses in agriculture and tourism, the expansion of informal settlements due to climate-induced migration, and the severe mental health trauma facing children. The author argues that without a rapid phase-out of fossil fuels, large parts of the country may become uninhabitable, leading to systemic social conflict and economic collapse.","ai_generated":true,"unit":"cer-000393#summary","date_modified":"2026-10-23"},"key_insights":[{"text":"South Africa is currently on a 'worst-case' trajectory, specifically Representative Concentration Pathway (RCP) 8.5, which predicts a global surface temperature increase of 3-4°C+ above the 20th century average by mid-century.","ai_generated":true,"unit":"cer-000393#insight-1","date_modified":"2026-10-23"},{"text":"Climate change will cause severe physical and ecological disruptions in South Africa, including more frequent heat extremes, extended droughts, increased fire risk, and more intense extreme rainfall events that may exceed historical infrastructure design specifications.","ai_generated":true,"unit":"cer-000393#insight-2","date_modified":"2026-10-23"},{"text":"Water scarcity and food insecurity will disproportionately affect children and women; girls may miss schooling due to increased time spent fetching water, and children are likely to suffer most from hunger and malnutrition.","ai_generated":true,"unit":"cer-000393#insight-3","date_modified":"2026-10-23"},{"text":"Coastal regions face significant threats from sea-level rise and ocean acidification, which will likely lead to the collapse of marine-based tourism and the necessity of 'managed retreats' from the coastline as properties become uninsurable.","ai_generated":true,"unit":"cer-000393#insight-4","date_modified":"2026-10-23"},{"text":"Climate-induced migration and the breakdown of social ties are expected to cause massive emotional trauma, depression, and hopelessness, particularly among youth, while expanding informal settlements may increase xenophobic violence.","ai_generated":true,"unit":"cer-000393#insight-5","date_modified":"2026-10-23"},{"text":"Regional analysis suggests that by 2041-2060, the Western Cape's agricultural and tourism sectors may be devastated, while the interior (Limpopo/Lephalale) could see the total collapse of rain-fed agriculture and commercial enterprises.","ai_generated":true,"unit":"cer-000393#insight-6","date_modified":"2026-10-23"},{"text":"In Mpumalanga, the transition away from coal without proactive 'just transition' planning, combined with climate stress and tropical cyclones, is predicted to cause unprecedented job losses and social upheaval.","ai_generated":true,"unit":"cer-000393#insight-7","date_modified":"2026-10-23"},{"text":"The report concludes that current systems are extremely vulnerable and that avoiding profound negative impacts on future generations requires an immediate transformational change in energy policy, including the cessation of fossil fuel use.","ai_generated":true,"unit":"cer-000393#insight-8","date_modified":"2026-10-23"}],"climate_tags":["greenhouse gas emissions","climate change adaptation","food insecurity","sea level rise","ocean acidification","climate migration","just transition","fossil fuel","renewable energy","extreme weather event","climate justice","public health","biodiversity loss"],"geography_discussed":["Southern Africa","Western Cape","Limpopo","Lephalale","Mpumalanga","Witbank","Khayalitsha","Mozambique"],"frame_perspective":[],"analysis_type":["impact assessment","regional projection","expert report"]},{"id":"cer-000231","url":"https://climateinsightsdirectory.org/document/cer-000231","title":"SUBMISSIONS ON THE GAS AMENDMENT BILL [B9 – 2020]","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":"2021-07-30","source_url":"https://cer.org.za/wp-content/uploads/2021/08/26-07-21-CER-comments-on-the-Gas-Amendment-Bill_.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"The CER and groundWork oppose the Gas Amendment Bill [B9-2020], asserting that it facilitates fossil fuel development contrary to South Africa's climate obligations and the 1.5°C target. They argue the Bill lacks meaningful public consultation, fails to provide adequate access to information, and irregularly grants environmental regulatory powers to the Energy Regulator, thereby encroaching on the mandate of the Minister of Forestry, Fisheries and Environment.","ai_generated":true,"unit":"cer-000231#summary","date_modified":"2026-10-23"},"key_insights":[{"text":"The Bill is deemed irrational because it facilitates new fossil fuel infrastructure at a time when South Africa must abandon fossil fuels to meet its constitutional obligations and international climate commitments under the Paris Agreement.","ai_generated":true,"unit":"cer-000231#insight-1","date_modified":"2026-10-23"},{"text":"The CER argues that gas is not a viable 'bridge fuel' because the 1.5°C target cannot be met with new gas development, and the greenhouse gas footprint of gas—particularly methane emissions—may be worse than coal or oil over a 20-year timescale.","ai_generated":true,"unit":"cer-000231#insight-2","date_modified":"2026-10-23"},{"text":"The Bill's consultation and objection processes are insufficient, specifically the 60-day time limit, which the CER claims prevents meaningful public participation and violates the constitutional right to fair administrative action.","ai_generated":true,"unit":"cer-000231#insight-3","date_modified":"2026-10-23"},{"text":"The Bill irregularly grants the Energy Regulator powers over compliance notices and environmental regulation, which the CER asserts violates the 'One Environmental System' (OES) and encroaches on the authority of the Minister of Forestry, Fisheries and Environment.","ai_generated":true,"unit":"cer-000231#insight-4","date_modified":"2026-10-23"},{"text":"The CER identifies a lack of transparency in the Bill, noting that interested parties are expected to object to license applications without having automatic access to the full application documents.","ai_generated":true,"unit":"cer-000231#insight-5","date_modified":"2026-10-23"}],"climate_tags":["climate change","greenhouse gas emissions","methane","Paris Agreement","energy transition","climate justice","environmental regulation","stranded asset","liquefied natural gas","compressed natural gas"],"geography_discussed":["Southern Africa"],"frame_perspective":[],"analysis_type":["policy analysis","legal submission"]},{"id":"cer-001604","url":"https://climateinsightsdirectory.org/document/cer-001604","title":"The just transition: A once-in-a-generation chance for real transformation that will save our country and our planet","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":"2021-07-30","source_url":"https://cer.org.za/news/the-just-transition-a-once-in-a-generation-chance-for-real-transformation-that-will-save-our-country-and-our-planet-2","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"The Centre for Environmental Rights asserts that South Africa's transition from coal must go beyond energy shifts to encompass a radical restructuring of society. The author warns that southern Africa is warming at twice the global rate, making incremental change impossible. The document advocates for an \"Open Agenda for a Just Transition\" that integrates clean energy with food sovereignty, gender justice, and a new economic system based on human needs rather than profit.","ai_generated":true,"unit":"cer-001604#summary","date_modified":"2026-10-23"},"key_insights":[{"text":"South Africa faces severe climate risks at a 1.5°C global temperature increase, including increased frequency of droughts, flash flooding, heatwaves, and infrastructure failure. Because southern Africa is warming at twice the global rate, a 3°C trajectory would be \"catastrophic\".","ai_generated":true,"unit":"cer-001604#insight-1","date_modified":"2026-10-23"},{"text":"The transition away from fossil fuels is already underway due to global capital shifts and plummeting local costs for renewable energy, rendering new fossil fuel investments \"indefensible\" in the current fiscal environment.","ai_generated":true,"unit":"cer-001604#insight-2","date_modified":"2026-10-23"},{"text":"The author criticizes the narrow interpretation of a \"just transition\" as merely protecting worker livelihoods, arguing this view is used as an \"excuse to slow down the pace of the transition\" and ignores existing job losses in the coal sector and toxic air pollution in the Mpumalanga Highveld.","ai_generated":true,"unit":"cer-001604#insight-3","date_modified":"2026-10-23"},{"text":"The \"Open Agenda for a Just Transition,\" released by the Life After Coal campaign, calls for a systemic shift toward a society based on social justice and clean energy. Key demands include ending financing for coal and gas, rehabilitating land and water ruined by mining, ensuring food sovereignty, and implementing universal basic income support.","ai_generated":true,"unit":"cer-001604#insight-4","date_modified":"2026-10-23"}],"climate_tags":["just transition","energy transition","coal","renewable energy","climate change adaptation","fossil fuel","natural gas","climate migrant","air pollution","climate finance"],"geography_discussed":["Mpumalanga Highveld","Southern Africa","World"],"frame_perspective":[],"analysis_type":["policy advocacy"]},{"id":"cer-000956","url":"https://climateinsightsdirectory.org/document/cer-000956","title":"Final Synthesis Report","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"report","language":"en","date_published":"2021-07-27","source_url":"https://cer.org.za/wp-content/uploads/2024/08/Final-report_SO2Panel_submit.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"The report evaluates the impact of SO2 emissions from large solid fuel combustion installations in South Africa, primarily those operated by Eskom and Sasol. It concludes that implementing stricter emission standards is technologically feasible and economically beneficial for society due to significant reductions in public health costs, despite the high capital costs for plant operators. The panel recommends a flexible regulatory approach where emission limits are tailored to the remaining lifetime of each plant, suggesting that plants operating beyond the mid-2030s should meet stricter limits of 250 mg/Nm3 or 500 mg/Nm3, while those retiring sooner may be granted more lenient limits of 1000 mg/Nm3. The report highlights that 'expedited retirement' of older coal capacity could reduce retrofit costs by approximately 25% and minimize electricity tariff increases.","ai_generated":true,"unit":"cer-000956#summary","date_modified":"2026-10-23"},"key_insights":[{"text":"Eskom and Sasol are the dominant sources of SO2 in South Africa, accounting for 99.7% of emissions from solid fuel combustion installations larger than 50MW.","ai_generated":true,"unit":"cer-000956#insight-1","date_modified":"2026-10-23"},{"text":"SO2 emissions from Eskom facilities alone are estimated to cause external health costs of 1135 billion rand per year across various studies.","ai_generated":true,"unit":"cer-000956#insight-2","date_modified":"2026-10-23"},{"text":"The panel identifies several mature technologies for SO2 reduction, with Wet Flue Gas Desulphurisation (Wet FGD) being the most common worldwide and most considered for limits of 500 mg/Nm3 or lower in South Africa due to high efficiency (>90%).","ai_generated":true,"unit":"cer-000956#insight-3","date_modified":"2026-10-23"},{"text":"A cost-benefit analysis (CBA) indicates that it is economically beneficial and technically feasible for all plants operating post-2030 to meet an MES of 1000 mg/Nm3 or lower, with most benefiting from limits of 250 mg/Nm3 or 500 mg/Nm3.","ai_generated":true,"unit":"cer-000956#insight-4","date_modified":"2026-10-23"},{"text":"The 'Expedited retirement' policy option is the most cost-effective, reducing upfront investment costs to R 240 billion and limiting electricity tariff increases to 6.2%.","ai_generated":true,"unit":"cer-000956#insight-5","date_modified":"2026-10-23"},{"text":"Implementing the 'BAT on all plants' scenario (250 mg/Nm3 limit) would reduce public health costs by 92% compared to doing nothing, but would require an upfront investment of R 606 billion and a 14.6% electricity tariff increase.","ai_generated":true,"unit":"cer-000956#insight-6","date_modified":"2026-10-23"},{"text":"The manufacturing sector, particularly the Minerals-Energy Complex (MEC), would be most affected by the resulting electricity tariff increases, with production costs rising between 4.99% and 14.3%.","ai_generated":true,"unit":"cer-000956#insight-7","date_modified":"2026-10-23"},{"text":"Retrofitting emission controls is projected to have a positive impact on employment, with the 'BAT on all plants' option creating an average of 23,000 construction jobs between 2025 and 2030.","ai_generated":true,"unit":"cer-000956#insight-8","date_modified":"2026-10-23"}],"climate_tags":["coal-fired power station","public health","energy transition","industrial emission"],"geography_discussed":["Highveld Priority Area","Vaal Triangle Priority Area","Mpumalanga","Limpopo","Gauteng","People's Republic of China","Japan","European Union"],"frame_perspective":[],"analysis_type":["cost-benefit analysis","policy assessment","macroeconomic impact assessment"]},{"id":"cer-000229","url":"https://climateinsightsdirectory.org/document/cer-000229","title":"THE CENTRE FOR ENVIRONMENTAL RIGHTS COMMENTS ON THE DRAFT NATIONAL MINE CLOSURE STRATEGY 2021","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":"2021-07-23","source_url":"https://cer.org.za/wp-content/uploads/2021/07/23-07-21-CER-submissions-on-the-Mine-Closure-Strategy_.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","analysis_type"],"summary":{"text":"The Centre for Environmental Rights (CER) supports the creation of a National Mine Closure Strategy but argues that the draft must prioritize 'mining affected communities' over 'mining dependent communities' and ensure that closure planning begins at the pre-feasibility stage. The CER emphasizes the need for meaningful public participation, the integration of land reform and economic diversification to support a just transition, and the alignment of the strategy with the National Environmental Management Act (NEMA) to prevent 'temporary closure' from becoming a gateway to mine abandonment.","ai_generated":true,"unit":"cer-000229#summary","date_modified":"2026-10-23"},"key_insights":[{"text":"The CER argues that the term 'mining dependent communities' is inappropriate because many people are affected by mining without benefiting from or depending on it; they propose using 'mining affected communities' instead.","ai_generated":true,"unit":"cer-000229#insight-1","date_modified":"2026-10-23"},{"text":"The CER contends that closure planning must start at the pre-feasibility stage and continue throughout the mine's operation to ensure that closure costs are factored into the calculation of a mine's economic viability.","ai_generated":true,"unit":"cer-000229#insight-2","date_modified":"2026-10-23"},{"text":"The document highlights a risk that 'temporary closure' or 'care and maintenance' status is used as a loophole for mine abandonment because the draft strategy does not explicitly mention the persistence of environmental and water-related licenses and obligations during this phase.","ai_generated":true,"unit":"cer-000229#insight-3","date_modified":"2026-10-23"},{"text":"The CER asserts that the definition of 'Life of Mine' should be expanded beyond the period of economic operation to include the time until all environmental and water impacts, including latent ones, cease to manifest.","ai_generated":true,"unit":"cer-000229#insight-4","date_modified":"2026-10-23"},{"text":"The CER recommends that the strategy prioritize land reform and access to land for those most affected by mining to address historical dispossession and inequality.","ai_generated":true,"unit":"cer-000229#insight-5","date_modified":"2026-10-23"},{"text":"The CER emphasizes that for the strategy to be effective, it must be inclusive of other government departments, specifically the Department of Forestry, Fisheries and the Environment (DFFE), the Department of Water and Sanitation (DWS), and the Department of Rural Development and Agriculture.","ai_generated":true,"unit":"cer-000229#insight-6","date_modified":"2026-10-23"}],"climate_tags":["just transition","economic diversity","environmental risk","water management"],"geography_discussed":[],"frame_perspective":[],"analysis_type":["policy critique","legal analysis"]},{"id":"cer-001096","url":"https://climateinsightsdirectory.org/document/cer-001096","title":"COMMENTS ON THE INTENDED DRAFT GUIDELINE FOR CONSIDERATION OF CLIMATE CHANGE IMPLICATIONS IN APPLICATIONS FOR ENVIRONMENTAL AUTHORISATIONS, ATMOSPHERIC EMISSIONS LICENSES AND WASTE MANAGEMENT LICENCES","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":"2021-07-23","source_url":"https://cer.org.za/wp-content/uploads/2021/07/LAC-Submission-National-Guideline-for-Climate-Change-Considerations_26-July-2021.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"The Centre for Environmental Rights (CER), representing groundWork and Earthlife Africa, submitted comments on July 23, 2021, regarding the Department of Forestry, Fisheries and the Environment's (DFFE) draft Guideline for considering climate change implications in environmental authorisations and licenses. While welcoming the initiative, the CER argues that the draft is insufficient to address the climate crisis and fails to meet the legal requirements of the Constitution and the National Environment Management Act (NEMA). The submission advocates for a 1.5°C warming limit as the primary benchmark for emissions assessments rather than Nationally Determined Contributions (NDCs), and calls for the inclusion of social costs of carbon and full lifecycle GHG emissions in project evaluations.","ai_generated":true,"unit":"cer-001096#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The CER contends that South Africa's Nationally Determined Contributions (NDCs) are an inadequate benchmark for assessing an activity's climate change mitigation impacts because they are based on executive discretion and may not align with a safe emission reduction pathway. The CER argues that the benchmark should instead be a 1.5°C warming limit, noting that the draft NDC update from March 30, 2021, is 'insufficient' and the 2015 NDC is 'highly insufficient' according to Climate Action Tracker.","ai_generated":true,"unit":"cer-001096#insight-1","date_modified":"2026-08-17"},{"text":"The submission urges the DFFE to require an assessment of the external and social costs of carbon emissions for proposed projects. The CER suggests using the USA's social cost of carbon (SCC) protocol or an equivalent methodology to quantify damages—such as impacts on GDP, biodiversity, and human health—that are typically not paid for by project proponents, aligning with the NEMA principle that costs of remedying pollution must be paid by those responsible.","ai_generated":true,"unit":"cer-001096#insight-2","date_modified":"2026-08-17"},{"text":"The CER argues that climate impact assessments must adopt a full lifecycle and cumulative approach rather than assessing activities in isolation. This includes examining the full footprint of a project, its effects on carbon sinks, and how a single proposal contributes to the cumulative effects of other past, current, and future projects.","ai_generated":true,"unit":"cer-001096#insight-3","date_modified":"2026-08-17"},{"text":"The CER emphasizes the need to integrate equity and socio-economic considerations into climate assessments, specifically focusing on vulnerable groups such as women, children, the elderly, and poor communities who disproportionately bear the brunt of climate impacts. They recommend that the Guideline explicitly require the identification of disproportionate impacts on these groups to enable proactive public participation.","ai_generated":true,"unit":"cer-001096#insight-4","date_modified":"2026-08-17"},{"text":"The submission recommends expanding the definition and assessment of 'stranded assets' to include risks related to the economics of renewable energy, stricter GHG emission limits, regulatory risks, and market changes. The CER notes that the impacts of stranded assets extend beyond owners to include costs to public funds and society through job losses and decommissioning.","ai_generated":true,"unit":"cer-001096#insight-5","date_modified":"2026-08-17"},{"text":"The CER suggests that the climate impact guidance should be extended beyond the DFFE's mandate to include other licensing processes, such as water use licensing, electricity generation licenses by the National Energy Regulator, and scheduled trade permitting by local governments, to ensure consistency across government decision-making.","ai_generated":true,"unit":"cer-001096#insight-6","date_modified":"2026-08-17"}],"climate_tags":["ghg emissions","nationally determined contributions (ndcs)","1.5°c warming limit","social cost of carbon","environmental impact assessment (eia)","stranded assets","climate justice","lifecycle assessment"],"geography_discussed":["Southern Africa"],"frame_perspective":[],"analysis_type":["policy_commentary","legal_submission"]},{"id":"cer-000667","url":"https://climateinsightsdirectory.org/document/cer-000667","title":"INTEGRATED RESOURCE PLAN 2019 AND THE MINISTERIAL DETERMINATION ON THE PROCUREMENT OF NEW GENERATION CAPACITY FROM RENEWABLES, STORAGE, GAS AND COAL","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":"2021-07-09","source_url":"https://cer.org.za/wp-content/uploads/2021/09/CER-letter-to-Minister-Mantashe-NERSA-9.7.21.docx.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","analysis_type"],"summary":{"text":"The Centre for Environmental Rights, representing groundWork, Vukani Environmental Justice Movement in Action, and the African Climate Alliance, has formally objected to the inclusion of new fossil fuel generation capacity—specifically 1500 MW of new coal—in South Africa's Integrated Resource Plan (IRP) 2019 and a September 2020 ministerial determination. The letter requests that the Minister of Mineral Resources and Energy clarify if the IRP 2019 will be updated by the end of 2021, citing a June 2021 announcement by President Ramaphosa to increase the NERSA generation licence exemption threshold to 100 MW. The authors argue this change could unlock over 5000 MW of embedded generation capacity not currently accounted for in the IRP 2019, necessitating a revision of the proposed energy mix.","ai_generated":true,"unit":"cer-000667#summary","date_modified":"2026-10-23"},"key_insights":[{"text":"The authors contend that the written justifications provided by the Department for the determination and by NERSA for its concurrence are not reasonable, rational, or lawful.","ai_generated":true,"unit":"cer-000667#insight-1","date_modified":"2026-10-23"},{"text":"A June 10, 2021, announcement by President Ramaphosa regarding the amendment of Schedule 2 of the Electricity Regulation Act, 2006 (ERA) to allow projects up to 100 MW to generate electricity without a NERSA licence may unlock more than 5000 MW of embedded generation capacity not included in the IRP 2019.","ai_generated":true,"unit":"cer-000667#insight-2","date_modified":"2026-10-23"}],"climate_tags":["coal","renewable energy","energy storage","natural gas","climate justice"],"geography_discussed":[],"frame_perspective":[],"analysis_type":["policy analysis","legal challenge"]},{"id":"cer-000637","url":"https://climateinsightsdirectory.org/document/cer-000637","title":"NERSA ELECTRICITY GENERATION LICENCE APPLICATIONS FOR KARPOWERSHIP RICHARD’S BAY, NGQURA AND SALDANHA","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"statement","language":"en","date_published":"2021-07-06","source_url":"https://cer.org.za/wp-content/uploads/2021/08/CER-letter-to-DFFE-re-Karpowership-EIA-suspension-6.07.2021.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"The Centre for Environmental Rights (CER), acting on behalf of groundwork, wrote to the National Energy Regulator SA (NERSA) on 6 July 2021 to request a 90-day extension for commenting on electricity generation licence applications for three Karpowership gas power projects. The CER argues that the public participation process is flawed and that the projects' national significance warrants wider advertisement beyond local newspapers.","ai_generated":true,"unit":"cer-000637#summary","date_modified":"2026-08-17"},"key_insights":[{"text":"The Centre for Environmental Rights (CER) is requesting a 90-day extension to comment on electricity generation licence applications for three Karpowership gas power projects, arguing that a 30-day period per application is insufficient because the projects are located in different areas with distinct environmental impacts and separate Environmental Impact Assessments.","ai_generated":true,"unit":"cer-000637#insight-1","date_modified":"2026-08-17"},{"text":"The CER contends that NERSA's reliance on local newspaper notices for public participation is inadequate given the national importance of the projects, which may impact electricity prices and the broader South African economy.","ai_generated":true,"unit":"cer-000637#insight-2","date_modified":"2026-08-17"},{"text":"The CER notes that on 13 July, environmental authorisations for all three Karpowership projects were refused, which they argue means an extension of the commenting period would not prejudice the applicants as the projects already face delays.","ai_generated":true,"unit":"cer-000637#insight-3","date_modified":"2026-08-17"},{"text":"The CER has requested clarity from NERSA regarding the exact deadline dates for comment submissions and the dates for any planned public hearings, noting that existing local newspaper advertisements contain conflicting dates.","ai_generated":true,"unit":"cer-000637#insight-4","date_modified":"2026-08-17"}],"climate_tags":["energy transition","gas power","environmental impact assessment","public participation"],"geography_discussed":["Richards Bay","Port of Ngqura","Saldanha Bay","Coega"],"frame_perspective":[],"analysis_type":["legal correspondence","policy advocacy"]},{"id":"cer-000426","url":"https://climateinsightsdirectory.org/document/cer-000426","title":"COMMENTS ON POTENTIAL IMPACTS OF PROPOSED NEW COAL GENERATION UNDER THE SOUTH AFRICA 2019 INTEGRATED RESOURCE PLAN","publisher":{"name":"Centre for Environmental Rights","organization":"centre-for-environmental-rights"},"document_type":"report","language":"en","date_published":"2021-07","source_url":"https://cer.org.za/wp-content/uploads/2021/09/Annexure-B_SAHU_SA_2019_IRP.pdf?x21779","generator":"Climate Insights Directory","generated_fields":["summary","key_insights","climate_tags","geography_discussed","analysis_type"],"summary":{"text":"The report argues that the 2019 IRP's goal of adding 1500 MW of new coal generation is technically and environmentally problematic. It concludes that 'clean coal' is a myth, as even high-efficiency, low-emission (HELE) technologies cannot eliminate significant air pollution and greenhouse gas emissions. The author finds that advanced ultra-supercritical plants and carbon capture technologies are currently unproven or cost-prohibitive at scale, making them unlikely to be implemented. Furthermore, the report asserts that the 2023 timeline for the first 750 MW is unrealistic and that new plants would inevitably cause harm to human and environmental health through emissions of toxic organic compounds, trace metals, and acid gases, as well as impacts from the broader coal supply chain.","ai_generated":true,"unit":"cer-000426#summary","date_modified":"2026-10-23"},"key_insights":[{"text":"Ultra-supercritical (USC) efficiency is the highest thermal cycle efficiency realistically achievable for the 1500 MW of new coal under the 2019 IRP, as advanced ultra-supercritical (AUSC) plants do not meet the IRP's requirement for operational project experience.","ai_generated":true,"unit":"cer-000426#insight-1","date_modified":"2026-10-23"},{"text":"Carbon capture (CC) technologies are considered impractical and unlikely to be implemented for the proposed capacity due to prohibitive costs, lack of commercial-scale operational success, and a significant energy penalty that reduces thermal efficiency by 8-10 percentage points.","ai_generated":true,"unit":"cer-000426#insight-2","date_modified":"2026-10-23"},{"text":"The concept of \"clean coal\" is described as a myth because emissions of toxic organic compounds, trace metals, and acid gases are inescapable, and the entire supply chain—from mining to ash disposal—creates significant environmental and health impacts.","ai_generated":true,"unit":"cer-000426#insight-3","date_modified":"2026-10-23"},{"text":"Circulating fluidized bed (CFB) technology, while preferred by the IRP for its ability to handle low-quality coal, emits significantly more nitrous oxide (N2O)—a potent greenhouse gas—than pulverized coal technologies.","ai_generated":true,"unit":"cer-000426#insight-4","date_modified":"2026-10-23"},{"text":"The 2019 IRP's timeline for bringing 750 MW of new coal generation online by 2023 is deemed unreasonable given the time required for technology selection, design, and procurement.","ai_generated":true,"unit":"cer-000426#insight-5","date_modified":"2026-10-23"},{"text":"Integrated gasification combined cycle (IGCC) and underground gasification combined cycle (UGCC) are unlikely candidates for the 2019 IRP due to high capital and operating costs and a lack of full-scale operating experience in South African conditions.","ai_generated":true,"unit":"cer-000426#insight-6","date_modified":"2026-10-23"}],"climate_tags":["coal-fired power station","carbon capture and storage","greenhouse gas emissions","nitrous oxide","air pollution","environmental impact of mercury","particulates"],"geography_discussed":["United States","Germany","People's Republic of China","South Korea","Japan","Canada","Finland"],"frame_perspective":[],"analysis_type":["technical assessment","environmental impact assessment"]}]}