2014-05-30-fa65-green-room-issues-15-05-2013-c19ba92f885f774b.pdf

This briefing document outlines technical and regulatory issues arising from a May 15, 2013, workshop between the Department of Environmental Affairs (DEA) and industry stakeholders regarding the Section 21 emission standards. It focuses on refining activity descriptions, adjusting emission limits for specific industrial processes, and addressing the legal and practical implications of including 'use of' and 'storage' in the listed activities.

• Industry stakeholders argue that the inclusion of the phrase "use of" in activity descriptions for chemical and metallurgical processes creates unintended regulatory burdens. This phrasing potentially triggers licensing requirements for activities that are not point sources of emissions, such as water treatment plants using acids for pH correction or farmers using phosphate salts.
• Anglo American Platinum (AAP) requests that the Metallurgical Industry (Category 4) be "ring-fenced" to include all related production processes and that the DEA recognize the 2010 Category 4.16 requirements to allow for a focus on meeting more stringent 2020 SO2 limits, as 2015 compliance is not feasible for the Polokwane and Mortimer smelters.
• There is a proposal to introduce a new combustion subcategory (1.x) for multi-fuel combustion installations that use conventional fuels and waste as defined in the Waste Act, 2008, provided the waste does not contain halogenated hydrocarbons or substances that produce specific pollutants like hydrogen chloride or mercury in flue gases.
• The document argues that bulk storage of hazardous chemicals should be removed from the Section 21 list because it is already controlled by EIA regulations and the National Framework for Air Quality Management (7 September 2007) specifies it should not be handled as a point source.
• Regarding primary aluminium production, it is proposed that separate SO2 limits be set for the carbon process (500 mg/Nm³) and the reduction process (250 mg/Nm³), as the proposed 50 mg/Nm³ limit for new plants is deemed technically impossible and is not imposed in Europe.
• The briefing requests the removal of explosives burning grounds from the Section 21 list, arguing that they are already regulated by the Explosives Act, 2003, and that regulating them as point sources is impractical and could force the cessation of explosives production due to storage limits.

APA

Centre for Environmental Rights (n.d.). 2014-05-30-fa65-green-room-issues-15-05-2013-c19ba92f885f774b.pdf. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA65-Green-Room-issues-15-05-2013.pdf?x21779

Chicago

Centre for Environmental Rights. 2014-05-30-fa65-green-room-issues-15-05-2013-c19ba92f885f774b.pdf. n.d. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA65-Green-Room-issues-15-05-2013.pdf?x21779.

Wikipedia

{{cite report |author=Centre for Environmental Rights |title=2014-05-30-fa65-green-room-issues-15-05-2013-c19ba92f885f774b.pdf |url=https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA65-Green-Room-issues-15-05-2013.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centreforenvironmentalrightsnd20140530fa65greenroomissues15052013c19ba92f885f774bpdf, author = {{Centre for Environmental Rights}}, title = {{2014-05-30-fa65-green-room-issues-15-05-2013-c19ba92f885f774b.pdf}}, institution = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA65-Green-Room-issues-15-05-2013.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }