SUBMISSIONS ON THE DRAFT NKANGALA AIR QUALITY MANAGEMENT PLAN

The Centre for Environmental Rights (CER) provides submissions on the first draft of the Nkangala District Municipality (NDM) Air Quality Management Plan (AQMP). The CER identifies significant gaps in technical and financial capacity, a lack of alignment with the Highveld Priority Area (HPA) AQMP, and deficiencies in health impact assessments and monitoring. The submissions call for the NDM to prioritize staffing, ensure transparency in air quality data, and implement stricter dust control regulations.

• The Nkangala District Municipality (NDM) suffers from a critical lack of technical and financial resources, specifically a shortage of skilled personnel needed to perform air quality functions. The CER argues that populating the AQM structure must be the first objective of the AQMP to ensure its implementation.
• The draft NDM AQMP is inconsistent and unaligned with the Highveld Priority Area (HPA) AQMP. For example, while the HPA AQMP set a 2015 deadline for optimizing government organizational capacity, the NDM draft extends this goal to 2018, which the CER suggests may lead to duplication of work and confusion.
• There is a total absence of ambient monitoring in the local municipalities of Victor Kanye, eMakhazeni, Thembisile, and Dr JS Moroka, with the draft document providing no explanation for this gap or steps to address it.
• The CER criticizes the current National Dust Control Regulations as ineffective for protecting human health and proposes that the NDM AQMP and associated by-laws implement a stricter regimen for regulating dust control.
• The CER requests that the AQMP explicitly guarantee stakeholder access to specific air quality information, including external audits, minutes of meetings, compliance/emission reports, and atmospheric emission licences (AELs).
• The CER argues that clean technologies should be a mandatory requirement rather than a recommendation within the AEL, contradicting the current indicator in the draft AQMP.
• The CER expresses concern over the use of 'Basa njengo Magogo (BnM)' as a tool to reduce domestic coal burning in low-income settlements, stating that BnM lacks the desired impact and that clean energy provision and improved housing are urgently needed.

APA

Centre for Environmental Rights (2015). SUBMISSIONS ON THE DRAFT NKANGALA AIR QUALITY MANAGEMENT PLAN. https://cer.org.za/wp-content/uploads/2016/08/Annexure-B-Draft-submissions-on-the-Draft-NDM-AQMP_final.pdf?x21779

Chicago

Centre for Environmental Rights. SUBMISSIONS ON THE DRAFT NKANGALA AIR QUALITY MANAGEMENT PLAN. 2015. https://cer.org.za/wp-content/uploads/2016/08/Annexure-B-Draft-submissions-on-the-Draft-NDM-AQMP_final.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=SUBMISSIONS ON THE DRAFT NKANGALA AIR QUALITY MANAGEMENT PLAN |date=April 2015 |url=https://cer.org.za/wp-content/uploads/2016/08/Annexure-B-Draft-submissions-on-the-Draft-NDM-AQMP_final.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2015submissions, author = {{Centre for Environmental Rights}}, title = {{SUBMISSIONS ON THE DRAFT NKANGALA AIR QUALITY MANAGEMENT PLAN}}, publisher = {Centre for Environmental Rights}, year = {2015}, month = apr, url = {https://cer.org.za/wp-content/uploads/2016/08/Annexure-B-Draft-submissions-on-the-Draft-NDM-AQMP_final.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }