PRELIMINARY SUBMISSIONS REGARDING THE DRAFT REVIEW OF THE NATIONAL FRAMEWORK FOR AIR QUALITY MANAGEMENT 2017

The Centre for Environmental Rights (CER), representing several environmental justice organizations, submitted preliminary comments on the 2017 draft review of South Africa's National Framework for Air Quality Management. The submission criticizes the Department of Environmental Affairs (DEA) for failing to meet previous targets, lacking transparency in progress reviews, and neglecting meaningful public participation in high-pollution priority areas.

• The CER asserts that many objectives of the National Environmental Management: Air Quality Act (AQA) remain unrealized 12 years after its promulgation. Specifically, the Vaal Triangle Airshed and Highveld Priority Areas continue to experience regular and significant exceedances of national ambient air quality standards (NAAQS) despite being declared 11 and 10 years ago, respectively. Additionally, the Waterberg-Bojanala priority area is out of compliance with NAAQS.
• The submission highlights a systemic failure by the Department of Environmental Affairs (DEA) to conduct comprehensive progress reviews against the 2007 and 2012 Frameworks. The CER notes that the 2017 draft Framework merely extends previous targets without explaining why they were not met or reviewing progress made.
• The CER identifies several specific delays in the implementation of air quality systems and strategies: the South African Air Quality Information System (SAAQIS) upgrade was extended to 2017/2018; the National Atmospheric Emission Inventory System (NAEIS) no longer has a listed deadline; and the National Ambient Air Quality Monitoring strategy was delayed from 2013/2014 to 2018/2019.
• The document criticizes the lack of public participation in priority areas where air quality is poorest. The CER argues that holding meetings only in major cities like Cape Town excludes vulnerable communities who lack the financial and technical resources to travel, violating the principles of the 2012 Framework.
• The CER raises concerns regarding Greenhouse Gas (GHG) reporting, arguing that the current regulations are deficient because they do not explicitly require reporting at an individual facility level. They also note that the final Pollution Prevention Plan regulations replaced the objective of reducing GHG emissions with a reference to 'deviation' from a baseline, which could be used to excuse high emissions.
• The submission points to a significant reduction in the number of monitoring stations required to report to the National Air Quality Index (NAQI), dropping from 80 government-owned stations in the 2012 Framework to 42 in the draft framework. The CER notes that some of these 42 stations do not monitor any pollutants.

APA

Centre for Environmental Rights (2017). PRELIMINARY SUBMISSIONS REGARDING THE DRAFT REVIEW OF THE NATIONAL FRAMEWORK FOR AIR QUALITY MANAGEMENT 2017. https://cer.org.za/wp-content/uploads/2016/08/CER-Comments-on-Framework-Review-29-Sept-2017.pdf?x21779

Chicago

Centre for Environmental Rights. PRELIMINARY SUBMISSIONS REGARDING THE DRAFT REVIEW OF THE NATIONAL FRAMEWORK FOR AIR QUALITY MANAGEMENT 2017. 2017. https://cer.org.za/wp-content/uploads/2016/08/CER-Comments-on-Framework-Review-29-Sept-2017.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=PRELIMINARY SUBMISSIONS REGARDING THE DRAFT REVIEW OF THE NATIONAL FRAMEWORK FOR AIR QUALITY MANAGEMENT 2017 |date=29 September 2017 |url=https://cer.org.za/wp-content/uploads/2016/08/CER-Comments-on-Framework-Review-29-Sept-2017.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2017preliminary, author = {{Centre for Environmental Rights}}, title = {{PRELIMINARY SUBMISSIONS REGARDING THE DRAFT REVIEW OF THE NATIONAL FRAMEWORK FOR AIR QUALITY MANAGEMENT 2017}}, publisher = {Centre for Environmental Rights}, year = {2017}, month = sep, url = {https://cer.org.za/wp-content/uploads/2016/08/CER-Comments-on-Framework-Review-29-Sept-2017.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }