sasol’s submission on the requirement fcr existing plants to meet new plant standards as well as other concerns reiating to the Listed Activities and Minimum Emission standards

Sasol argues that retrofitting old plants to meet new emission standards is often technically impossible due to space and configuration constraints, and economically unjustifiable given the negligible impact on ambient air quality in some areas. The company highlights conflicts between air quality standards and national energy efficiency and waste strategies, while calling for extended compliance timelines and greater regulatory certainty across national, provincial, and local government tiers.

• Retrofitting old plants built between 1950 and 1980 to meet new plant standards is often impossible due to size and configuration constraints, and technology incompatibility means performance may not match new plants.
• Installing bulky abatement technology is frequently unfeasible because existing facilities are already optimized for space, meaning production areas would need to be demolished to make room for equipment.
• Compliance with new plant standards may increase South Africa's carbon footprint due to the energy requirements of abatement equipment and negative impacts on process efficiencies, contradicting the Department of Energy's National Energy Efficiency Strategy.
• The requirement to prohibit co-feeding small volumes of waste into boilers contradicts the Waste Act's goal of recovering energy from waste, as it forces operators to use more coal and send waste to landfills.
• Sasol asserts that the current compliance timeframes are too optimistic, as the design, construction, and commissioning of sites for unique older assets typically takes more than five years.
• There is significant regulatory uncertainty regarding the postponement clause, as legal opinions suggest postponements are limited to five years and can be withdrawn at any time, which discourages long-term investment.
• The ability of three tiers of government to independently set stricter standards creates a volatile investment landscape and the potential for contradictory legislation.

APA

Centre for Environmental Rights (n.d.). sasol’s submission on the requirement fcr existing plants to meet new plant standards as well as other concerns reiating to the Listed Activities and Minimum Emission standards. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA57-Email-from-SASOL-to-DEA-20-11-2013.pdf?x21779

Chicago

Centre for Environmental Rights. sasol’s submission on the requirement fcr existing plants to meet new plant standards as well as other concerns reiating to the Listed Activities and Minimum Emission standards. n.d. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA57-Email-from-SASOL-to-DEA-20-11-2013.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=sasol’s submission on the requirement fcr existing plants to meet new plant standards as well as other concerns reiating to the Listed Activities and Minimum Emission standards |url=https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA57-Email-from-SASOL-to-DEA-20-11-2013.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsndsasols, author = {{Centre for Environmental Rights}}, title = {{sasol’s submission on the requirement fcr existing plants to meet new plant standards as well as other concerns reiating to the Listed Activities and Minimum Emission standards}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA57-Email-from-SASOL-to-DEA-20-11-2013.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }