2014-05-30-fa59-letter-sasol-to-dea-23-01-2013-e217670012542108.pdf

A letter from Sasol to the South African Department of Environmental Affairs (DEA) providing comments on proposed amendments to the GN 248 List of Activities regarding atmospheric emissions. Sasol expresses support for the industry submission by CAIA/BUSA and highlights four primary concerns regarding the feasibility of standards for existing plants, compliance timelines, changes to activity scopes, and the alignment between waste and air quality regulations.

• Sasol argues that requiring existing plants to meet the same standards as new plants is "technically impractical and operationally infeasible" because older site layouts lack the space or utilities for bulky abatement equipment. The company requests the deletion of regulation (10) to provide investment certainty, asserting that standards for new and existing plants "can never converge".
• Sasol contends that the proposed compliance dates in GN964 are inconsistent and create uncertainty. The company supports the BUSA position that all compliance dates should be updated to five and ten years from the final date of promulgation, noting that it is "unreasonable to expect significant capital approvals and investments" when the standards are subject to substantive amendments that change project scopes.
• The document identifies concerns regarding substantive changes to the scope of listed activities, specifically that changes in application descriptions to include "use of" in sub-categories 4.20, 7.1, 7.2, 7.4 and 7.6 create overlaps and introduce new categories. Additionally, Sasol notes that sub-category 7.7 is a new category that requires a standard setting process as outlined in the National Air Quality Framework (NAQF).
• Sasol warns that a proposal to exclude waste from being co-fed into combustion installations would force energy generators to use more non-renewable resources like coal and gas. The company claims it is "financially and technically impossible" for large-scale combustion equipment to meet the standards of sub-category 8.1, which were designed for incinerators, and calls for alignment between the Waste and Air Quality sub-directorates.

APA

Centre for Environmental Rights (n.d.). 2014-05-30-fa59-letter-sasol-to-dea-23-01-2013-e217670012542108.pdf. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA59-Letter-SASOL-to-DEA-23-01-2013.pdf?x21779

Chicago

Centre for Environmental Rights. 2014-05-30-fa59-letter-sasol-to-dea-23-01-2013-e217670012542108.pdf. n.d. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA59-Letter-SASOL-to-DEA-23-01-2013.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=2014-05-30-fa59-letter-sasol-to-dea-23-01-2013-e217670012542108.pdf |url=https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA59-Letter-SASOL-to-DEA-23-01-2013.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsnd20140530fa59lettersasoltodea23012013e217670012542108pdf, author = {{Centre for Environmental Rights}}, title = {{2014-05-30-fa59-letter-sasol-to-dea-23-01-2013-e217670012542108.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA59-Letter-SASOL-to-DEA-23-01-2013.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }