REPRESENTATIONS ON THE NOTICE OF INTENTION TO AMEND THE LIST OF ACTIVITIES WHICH RESULT IN ATMOSPHERIC EMISISONS WHICH HAVE OR MAY HAVE A SIGNFICANT DETRIMENTAL EFFECT ON THE ENVIRONMENT, INCLUDING HEALTH, SOCIAL CONDITIONS, ECONOMIC CONDITIONS, ECOLOGICAL CONDITIONS OR CULTURAL HERITAGE

The Centre for Environmental Rights, representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted representations on June 25, 2018, regarding proposed amendments to the List of Activities resulting in atmospheric emissions. While supporting the elimination of 'rolling postponements' for minimum emission standards (MES), the submission argues for stricter requirements for once-off suspensions, greater transparency in application documents, and a more robust public participation process.

• The Life After Coal/Impilo Ngaphandle Kwamalahle Campaign supports draft amendments that eliminate opportunities to postpone compliance with existing plant minimum emission standards (MES) and end 'rolling postponements'—the practice of re-applying for postponements every 5 years until decommissioning.
• The submission argues that the List of Activities should incorporate requirements from the 2012 National Framework for Air Quality Management, specifically that postponements should only be granted if ambient air quality standards are in compliance and will remain so. It asserts that industries in the Vaal Triangle, Highveld, and Waterberg-Bojanala Priority Areas should be prohibited from applying for postponements due to existing non-compliance with National Ambient Air Quality Standards (NAAQS).
• The Campaign demands that all application documents for postponements or suspensions, including 'clear decommissioning schedules', be made publicly available for comment to ensure meaningful participation by interested and affected parties.
• For facilities seeking a once-off suspension, the submission proposes that they be required to meet emission standards stricter than existing plant MES, informed by a health risk assessment, and that these facilities must be decommissioned by 2030 at the latest.
• The submission recommends that decisions on postponement or suspension applications be made at least six months before the compliance date to allow industry sufficient time for planning, investment, and retrofitting.
• The Centre for Environmental Rights objects to the public consultation process, stating that the 30-day window to comment on three major air quality documents simultaneously was insufficient and inconsistent with the National Environmental Management Act, 1998, and the Constitution.

APA

Centre for Environmental Rights (2018). REPRESENTATIONS ON THE NOTICE OF INTENTION TO AMEND THE LIST OF ACTIVITIES WHICH RESULT IN ATMOSPHERIC EMISISONS WHICH HAVE OR MAY HAVE A SIGNFICANT DETRIMENTAL EFFECT ON THE ENVIRONMENT, INCLUDING HEALTH, SOCIAL CONDITIONS, ECONOMIC CONDITIONS, ECOLOGICAL CONDITIONS OR CULTURAL HERITAGE. https://cer.org.za/wp-content/uploads/2019/07/Annexure-1_CER_submissions_of_25_June_2018.pdf?x21779

Chicago

Centre for Environmental Rights. REPRESENTATIONS ON THE NOTICE OF INTENTION TO AMEND THE LIST OF ACTIVITIES WHICH RESULT IN ATMOSPHERIC EMISISONS WHICH HAVE OR MAY HAVE A SIGNFICANT DETRIMENTAL EFFECT ON THE ENVIRONMENT, INCLUDING HEALTH, SOCIAL CONDITIONS, ECONOMIC CONDITIONS, ECOLOGICAL CONDITIONS OR CULTURAL HERITAGE. 2018. https://cer.org.za/wp-content/uploads/2019/07/Annexure-1_CER_submissions_of_25_June_2018.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=REPRESENTATIONS ON THE NOTICE OF INTENTION TO AMEND THE LIST OF ACTIVITIES WHICH RESULT IN ATMOSPHERIC EMISISONS WHICH HAVE OR MAY HAVE A SIGNFICANT DETRIMENTAL EFFECT ON THE ENVIRONMENT, INCLUDING HEALTH, SOCIAL CONDITIONS, ECONOMIC CONDITIONS, ECOLOGICAL CONDITIONS OR CULTURAL HERITAGE |date=25 June 2018 |url=https://cer.org.za/wp-content/uploads/2019/07/Annexure-1_CER_submissions_of_25_June_2018.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2018representations, author = {{Centre for Environmental Rights}}, title = {{REPRESENTATIONS ON THE NOTICE OF INTENTION TO AMEND THE LIST OF ACTIVITIES WHICH RESULT IN ATMOSPHERIC EMISISONS WHICH HAVE OR MAY HAVE A SIGNFICANT DETRIMENTAL EFFECT ON THE ENVIRONMENT, INCLUDING HEALTH, SOCIAL CONDITIONS, ECONOMIC CONDITIONS, ECOLOGICAL CONDITIONS OR CULTURAL HERITAGE}}, publisher = {Centre for Environmental Rights}, year = {2018}, month = jun, url = {https://cer.org.za/wp-content/uploads/2019/07/Annexure-1_CER_submissions_of_25_June_2018.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }