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REGULATIONS FOR IMPLEMENTING AND ENFORCING THE HIGHVELD PRIORITY AREA AIR QUALITY MANAGEMENT PLAN (2012)

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This document consists of a series of letters and a report summary from the Centre for Environmental Rights (CER) addressed to the South African Department of Environmental Affairs (DEA). The CER, representing various environmental groups, argues that the Highveld Priority Area (HPA) has failed to improve air quality since its 2007 declaration. The CER demands the urgent implementation of regulations to enforce the 2012 Air Quality Management Plan (AQMP), the elimination of 'rolling postponements' for emission standards granted to major polluters like Eskom and Sasol, and a formal response to the 'Broken Promises' report regarding the ongoing violation of constitutional rights to a healthy environment.

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  • Air quality in the Highveld Priority Area (HPA) has not shown significant improvement in the decade following its 2007 declaration, with ambient data continuing to show significant exceedances of health-based National Ambient Air Quality Standards (NAAQS).
  • The 2012 Air Quality Management Plan (AQMP) has effectively functioned as a guideline rather than an enforceable mandate because the Department of Environmental Affairs (DEA) failed to prescribe the necessary implementation and enforcement regulations under section 20 of the Air Quality Act.
  • The HPA's air quality monitoring network has significantly deteriorated; while the 2012 AQMP listed 23 monitoring sites with data, a 2017 draft review listed only nine, with only five of those providing timely monthly reports via the South African Air Quality Information System (SAAQIS).
  • Major industrial polluters, specifically Eskom and Sasol, have benefited from 'rolling postponements' of compliance with minimum emission standards (MES), which the CER argues sustains a state of non-compliance and violates section 24 of the Constitution.
  • The HPA has failed to meet its specific AQMP goals, including Goal 1 (optimising government organisational capacity by 2015) and Goal 2 (equitably reducing industrial emissions by 2020).
  • Expert analysis indicates severe health and economic burdens due to air pollution from coal-fired power stations, including an estimated 2,239 equivalent attributable deaths and an annual economic cost of approximately R33 billion.

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APA
Centre for Environmental Rights (2018). REGULATIONS FOR IMPLEMENTING AND ENFORCING THE HIGHVELD PRIORITY AREA AIR QUALITY MANAGEMENT PLAN (2012). https://cer.org.za/wp-content/uploads/2019/05/CER-Letter-to-Minister-Mokonyane_10-December-2018.pdf?x21779
Chicago
Centre for Environmental Rights. REGULATIONS FOR IMPLEMENTING AND ENFORCING THE HIGHVELD PRIORITY AREA AIR QUALITY MANAGEMENT PLAN (2012). 2018. https://cer.org.za/wp-content/uploads/2019/05/CER-Letter-to-Minister-Mokonyane_10-December-2018.pdf?x21779.
Wikipedia
{{cite press release |author=Centre for Environmental Rights |title=REGULATIONS FOR IMPLEMENTING AND ENFORCING THE HIGHVELD PRIORITY AREA AIR QUALITY MANAGEMENT PLAN (2012) |date=10 December 2018 |url=https://cer.org.za/wp-content/uploads/2019/05/CER-Letter-to-Minister-Mokonyane_10-December-2018.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}
BibTeX
@misc{centreforenvironmentalrights2018regulations, author = {{Centre for Environmental Rights}}, title = {{REGULATIONS FOR IMPLEMENTING AND ENFORCING THE HIGHVELD PRIORITY AREA AIR QUALITY MANAGEMENT PLAN (2012)}}, publisher = {Centre for Environmental Rights}, year = {2018}, month = dec, url = {https://cer.org.za/wp-content/uploads/2019/05/CER-Letter-to-Minister-Mokonyane_10-December-2018.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }

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