OPPOSITION TO THE ESTABLISHMENT OF AN EXPERT PANEL ON SULPHUR DIOXIDE (SO2) ABATEMENT SOLUTIONS

The Centre for Environmental Rights (CER), representing several environmental justice organizations, formally opposes the Department of Environmental Affairs' (DEA) proposal to establish an expert panel to find solutions for sulphur dioxide (SO2) abatement. The CER argues that such a panel would unnecessarily delay compliance with Minimum Emission Standards (MES), duplicate previous multi-stakeholder processes, and potentially lead to an unlawful weakening of environmental standards for major polluters Eskom and Sasol.

• The Centre for Environmental Rights (CER) and its clients—groundWork (gW), Earthlife Africa Johannesburg (ELA), the Highveld Environmental Justice Network (HEJN), and the Vaal Environmental Justice Alliance (VEJA)—object to the creation of a technical expert panel to resolve compliance issues regarding sulphur dioxide (SO2) Minimum Emission Standards (MES). The CER contends that Eskom and Sasol, the two largest polluters in the country, have already received multiple postponements and intend to seek more, despite indicating they do not intend to meet the new plant SO2 MES.
• The CER argues that establishing an expert panel will only serve to delay necessary actions to achieve MES compliance. They assert that the required solution is already known: Eskom and Sasol must either retrofit their plants with SO2 abatement technology or implement an expedited plan to decommission plants that cannot meet the standards.
• The proposed panel is viewed as a duplication of a five-year multi-stakeholder consultation process used to set the MES. This process, which included Eskom and Sasol, considered technical feasibility, socio-economic consequences, and health objectives. The CER notes that flue gas desulphurisation (FGD) was already identified as the Best Available Technology (BAT) to meet the new plant SO2 MES.
• South African SO2 emission standards are described as exceptionally weak compared to other nations. Existing plant MES are 17.5 times weaker than those in Germany, the European Union (EU), and China, and nearly 6 times weaker than India's. New plant MES are more than 14 times weaker than China's, 5 times weaker than India's, and more than 3 times weaker than those in Germany and the EU.
• The CER asserts that there is no legislative provision allowing the DEA to weaken the MES or exempt industry from legal requirements based on claims that compliance is 'practically infeasible' or challenging for 'Brownfields' sites. They maintain that the constitutional right to an environment not harmful to health cannot be infringed upon due to the costs of adapting plants.

APA

Centre for Environmental Rights (2018). OPPOSITION TO THE ESTABLISHMENT OF AN EXPERT PANEL ON SULPHUR DIOXIDE (SO2) ABATEMENT SOLUTIONS. https://cer.org.za/wp-content/uploads/2019/07/Annexure-2_CER_letter_to_DEA_re_SO2_panel_5_March_2018.pdf?x21779

Chicago

Centre for Environmental Rights. OPPOSITION TO THE ESTABLISHMENT OF AN EXPERT PANEL ON SULPHUR DIOXIDE (SO2) ABATEMENT SOLUTIONS. 2018. https://cer.org.za/wp-content/uploads/2019/07/Annexure-2_CER_letter_to_DEA_re_SO2_panel_5_March_2018.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=OPPOSITION TO THE ESTABLISHMENT OF AN EXPERT PANEL ON SULPHUR DIOXIDE (SO2) ABATEMENT SOLUTIONS |date=5 March 2018 |url=https://cer.org.za/wp-content/uploads/2019/07/Annexure-2_CER_letter_to_DEA_re_SO2_panel_5_March_2018.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2018opposition, author = {{Centre for Environmental Rights}}, title = {{OPPOSITION TO THE ESTABLISHMENT OF AN EXPERT PANEL ON SULPHUR DIOXIDE (SO2) ABATEMENT SOLUTIONS}}, publisher = {Centre for Environmental Rights}, year = {2018}, month = mar, url = {https://cer.org.za/wp-content/uploads/2019/07/Annexure-2_CER_letter_to_DEA_re_SO2_panel_5_March_2018.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }