CER COMMENTS ON THE UPDATED MULTI-STAKEHOLDER REFERENCE GROUP TERMS OF REFERENCE FOR THE IMPLEMENTATION OF THE HIGHVELD PRIORITY AREA AIR QUALITY MANAGEMENT PLAN

The Centre for Environmental Rights (CER), acting on behalf of several community and environmental organisations, submitted comments on 11 December 2015 regarding the updated Terms of Reference (ToR) for the implementation of the Highveld Priority Area (HPA) Air Quality Management Plan (AQMP). The CER argues that the ToR must be expanded to ensure broader government participation, mandatory attendance from industry and municipal leaders, and improved transparency and accessibility of air quality data and meeting documentation.

• The CER asserts that the roles and responsibilities in the updated ToR should be expanded to include specific government stakeholders whose mandates are necessary to achieve the HPA AQMP goals. These include the Department of Mineral Resources (DMR), the Department of Water Services and Sanitation (DWS), the Department of Energy (DOE), the Department of Health, and the Department of Transport.
• The CER identifies a lack of consistent attendance at Multi-stakeholder Reference Group (MSRG) meetings by Chairpersons of Implementation Task Team meetings and industry representatives. The CER proposes that attendance for these parties be made compulsory in the ToR to ensure reporting on municipal air quality and accountability for emission reductions.
• The CER requests specific amendments to the management of MSRG meetings to increase transparency and community input. These requests include allowing community-based organisations (CBOs) and NGOs to input into draft agendas, establishing standing agenda items for progress reports and compliance monitoring, and ensuring minutes and attendance registers are circulated within two weeks.
• The CER highlights a critical lack of public access to Atmospheric Emission Licences (AELs) and compliance reports. While the South African Air Quality Information System (SAAQIS) and the South African Atmospheric Emission Licensing and Inventory Portal (SAAELIP) exist, the CER states that neither provides public access to AELs or compliance reports.

APA

Centre for Environmental Rights (2015). CER COMMENTS ON THE UPDATED MULTI-STAKEHOLDER REFERENCE GROUP TERMS OF REFERENCE FOR THE IMPLEMENTATION OF THE HIGHVELD PRIORITY AREA AIR QUALITY MANAGEMENT PLAN. https://cer.org.za/wp-content/uploads/2020/06/Annexure-C.pdf?x21779

Chicago

Centre for Environmental Rights. CER COMMENTS ON THE UPDATED MULTI-STAKEHOLDER REFERENCE GROUP TERMS OF REFERENCE FOR THE IMPLEMENTATION OF THE HIGHVELD PRIORITY AREA AIR QUALITY MANAGEMENT PLAN. 2015. https://cer.org.za/wp-content/uploads/2020/06/Annexure-C.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=CER COMMENTS ON THE UPDATED MULTI-STAKEHOLDER REFERENCE GROUP TERMS OF REFERENCE FOR THE IMPLEMENTATION OF THE HIGHVELD PRIORITY AREA AIR QUALITY MANAGEMENT PLAN |date=11 December 2015 |url=https://cer.org.za/wp-content/uploads/2020/06/Annexure-C.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2015cer, author = {{Centre for Environmental Rights}}, title = {{CER COMMENTS ON THE UPDATED MULTI-STAKEHOLDER REFERENCE GROUP TERMS OF REFERENCE FOR THE IMPLEMENTATION OF THE HIGHVELD PRIORITY AREA AIR QUALITY MANAGEMENT PLAN}}, publisher = {Centre for Environmental Rights}, year = {2015}, month = dec, url = {https://cer.org.za/wp-content/uploads/2020/06/Annexure-C.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }