2014-05-30-fa32-caia-submission-08-2009-580ce04bc7792f42.pdf

The Chemical and Allied Industries Association (CAIA) submitted this statement in August 2009 to express concerns regarding a draft Notice on atmospheric emission limits. CAIA argues that the proposed standards are overly stringent, lack a Regulatory Impact Assessment, and deviate from previous working documents. The association advocates for flexible compliance timeframes, the ability to apply for exemptions based on site-specific impact reports, and the adoption of realistic minimum emission standards that consider technical feasibility and overall environmental footprints.

• CAIA requests that the draft Notice undergo a Regulatory Impact Assessment before finalisation to evaluate the potential socio-economic consequences and alternatives to the proposed stringent emission limits.
• The association argues that mandatory minimum performance levels should be based on risk management, proposing that applicants unable to meet timeframes be allowed to apply for extensions or exemptions via site-specific improvement plans and impact reports.
• CAIA identifies several factors that should influence the timeframes for meeting new plant standards, including the availability of technology, capital, skilled labour, engineering contractors, natural resources, and plot space, as well as product supply considerations during plant downtime.
• For the petroleum industry, CAIA proposes a new plant standard of 1.2 kg SO₂/ton crude to align South African refineries with EU refineries, noting that retrofitting existing facilities to Best Available Techniques (BAT) levels is not economically viable or technically possible.
• CAIA argues that flaring should be excluded from 'bubble' calculations for SO₂ and NOx emissions because direct measurement of flare gas composition is not possible and estimating efficiency is not a scientific approach for legislative requirements.
• For coal-to-liquids (CTL) facilities, CAIA opposes a Hydrogen Sulphide (H2S) emission limit of 5mg/Nm³ for new facilities, stating that achieving this would require Selective Rectisol technology with capital costs exceeding R17 billion in 2013.

APA

Centre for Environmental Rights (n.d.). 2014-05-30-fa32-caia-submission-08-2009-580ce04bc7792f42.pdf. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA32-CAIA-Submission-08-2009.pdf?x21779

Chicago

Centre for Environmental Rights. 2014-05-30-fa32-caia-submission-08-2009-580ce04bc7792f42.pdf. n.d. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA32-CAIA-Submission-08-2009.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=2014-05-30-fa32-caia-submission-08-2009-580ce04bc7792f42.pdf |url=https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA32-CAIA-Submission-08-2009.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsnd20140530fa32caiasubmission082009580ce04bc7792f42pdf, author = {{Centre for Environmental Rights}}, title = {{2014-05-30-fa32-caia-submission-08-2009-580ce04bc7792f42.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA32-CAIA-Submission-08-2009.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }