2014-05-30-fa61-revised-busa-submission-32b0a89bc77f0c70.pdf

This document is a revised submission by Business Unity South Africa (BUSA) providing detailed comments and proposed amendments to a draft Notice regarding activities resulting in atmospheric emissions. BUSA argues that the proposed emission limits and compliance timeframes are often technically and financially unfeasible, potentially harming the economic viability of the industrial and mining sectors during a period of manufacturing decline.

• BUSA asserts that the current draft Notice imposes emission limits that are "technically and financially challenging if not impossible to achieve," which threatens the economic viability of the mining and industrial sectors.
• BUSA argues that the proposed two-year compliance timeframe for existing plants to meet more stringent standards is insufficient for the necessary re-engineering and budgeting cycles.
• The submission highlights a lack of legal certainty regarding the postponement of compliance timeframes, noting that the current wording may not allow for multiple postponements despite verbal assurances from the Department.
• Regarding primary aluminium production (Subcategory 4.3), BUSA claims a proposed limit of 50 mg/Nm³ for new plants is "technically impossible" and exceeds standards imposed in Europe.
• BUSA requests the removal of bulk storage of hazardous chemicals from the Notice, arguing it is already controlled by EIA regulations and should be managed via a standard under Section 24(10) of NEMA.
• The submission argues that the removal of the 10 kg/hour threshold in Subcategory 8.1 (Thermal treatment of hazardous and general waste) inappropriately regulates small burners with no significant environmental impact.
• BUSA contends that burning grounds for explosives (Subcategory 8.3) should be removed from the Notice because they are already regulated by the Explosives Act, 2003, and cannot be managed as point sources.
• BUSA identifies a technical gap in compliance monitoring, stating that SANAS does not currently have a specific accreditation methodology for the calibration of online monitoring equipment, making the required two-yearly audits impossible.

APA

Centre for Environmental Rights (n.d.). 2014-05-30-fa61-revised-busa-submission-32b0a89bc77f0c70.pdf. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA61-Revised-BUSA-submission.pdf?x21779

Chicago

Centre for Environmental Rights. 2014-05-30-fa61-revised-busa-submission-32b0a89bc77f0c70.pdf. n.d. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA61-Revised-BUSA-submission.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=2014-05-30-fa61-revised-busa-submission-32b0a89bc77f0c70.pdf |url=https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA61-Revised-BUSA-submission.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsnd20140530fa61revisedbusasubmission32b0a89bc77f0c70pdf, author = {{Centre for Environmental Rights}}, title = {{2014-05-30-fa61-revised-busa-submission-32b0a89bc77f0c70.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA61-Revised-BUSA-submission.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }