SUBMISSIONS ON THE REVISED DRAFT AIR QUALITY MANAGEMENT PLAN “ANNEXURE 2”

The Centre for Environmental Rights (CER) submitted comments on the revised draft Air Quality Management Plan (AQMP) for the Nkangala District Municipality (NDM). The CER argues that the plan is overly ambitious given the NDM's lack of capacity and resources, fails to align with the Highveld Priority Area (HPA) AQMP, and contains significant technical errors in its air quality modelling and data.

• The draft AQMP is considered overly ambitious because it does not account for the NDM's lack of capacity and resources, which may prevent the municipality from meeting specified timeframes for interventions.
• There is a critical lack of coordination between the NDM AQMP and the Highveld Priority Area (HPA) AQMP, leading to risks of duplicated efforts and wasted resources.
• The CER identified several technical flaws in the AQMP's data, including incorrect PM10 compliance timeframes, outdated Benzene standards, and poor modelling domain selection for Doornkop and Vosman.
• The air quality modelling results correlate poorly with observed ambient concentrations, partly due to the exclusion of significant sources and large data gaps.
• The NDM lacks an effective enforcement strategy and sufficient personnel, with only 3 officials currently allocated to all regulatory functions for air quality management.
• Ambient air monitoring is reportedly absent in the local municipalities of Dr JS Moroka, Thembisile Hani, eMakhazeni, and Victor Khanye.
• The CER recommends that the NDM conduct an in-depth health impact assessment to determine the effects of indoor and outdoor combustion, as the current baseline study relies on external HPA studies.

APA

Centre for Environmental Rights (n.d.). SUBMISSIONS ON THE REVISED DRAFT AIR QUALITY MANAGEMENT PLAN “ANNEXURE 2”. https://cer.org.za/wp-content/uploads/2016/08/Annexure-2-CER-submissions-on-the-updated-NDM-AQMP-dated-6-May-2015-27-May-2015.pdf?x21779

Chicago

Centre for Environmental Rights. SUBMISSIONS ON THE REVISED DRAFT AIR QUALITY MANAGEMENT PLAN “ANNEXURE 2”. n.d. https://cer.org.za/wp-content/uploads/2016/08/Annexure-2-CER-submissions-on-the-updated-NDM-AQMP-dated-6-May-2015-27-May-2015.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=SUBMISSIONS ON THE REVISED DRAFT AIR QUALITY MANAGEMENT PLAN “ANNEXURE 2” |url=https://cer.org.za/wp-content/uploads/2016/08/Annexure-2-CER-submissions-on-the-updated-NDM-AQMP-dated-6-May-2015-27-May-2015.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsndsubmissions, author = {{Centre for Environmental Rights}}, title = {{SUBMISSIONS ON THE REVISED DRAFT AIR QUALITY MANAGEMENT PLAN “ANNEXURE 2”}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2016/08/Annexure-2-CER-submissions-on-the-updated-NDM-AQMP-dated-6-May-2015-27-May-2015.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }