REQUEST FOR REASONS FOR THE AMENDMENT OF SUBCATEGORY 1.1: SOLID FUEL COMBUSTION INSTALLATIONS IN THE LISTED ACTIVITIES AND ASSOCIATED MINIMUM EMISSION STANDARDS

The Centre for Environmental Rights, acting for groundWork and Earthlife Africa NPC, has formally requested written reasons from the South African Minister of Environment, Forestry and Fisheries regarding an amendment to the Minimum Emission Standards (MES). The amendment, published on 27 March 2020, doubles the permissible sulphur dioxide (SO2) limit for existing solid-fuel combustion installations, which the authors argue is unconstitutional and unlawful.

• An amendment to the Listed Activities, published under Government Notice No. 421 on 27 March 2020, increases the permissible sulphur dioxide (SO2) limit for existing solid-fuel combustion plants from 500mg/Nm3 to 1000mg/Nm3, effective from 1 April 2020. This change primarily benefits Sasol's coal-fired boilers and all of Eskom's coal-fired stations.
• The Centre for Environmental Rights, on behalf of groundWork and Earthlife Africa NPC, contends that the decision to weaken the SO2 MES limit is "unconstitutional, unlawful and invalid," asserting that it cannot be justified regardless of the considerations provided by the Department of Environment, Forestry and Fisheries.
• Invoking section 5(1) of the Promotion of Administrative Justice Act 3 of 2000 (PAJA), the authors have requested written reasons for the amendment by 4 May 2020. Specifically, they seek the data supporting the claim that a 1000mg/Nm3 limit will achieve a 58% reduction in total emissions, details of the Technical and Cost Benefit Analysis conducted by independent scientists, and a list of facilities built before 2010 that will not be decommissioned by 2030.

APA

Centre for Environmental Rights (2020). REQUEST FOR REASONS FOR THE AMENDMENT OF SUBCATEGORY 1.1: SOLID FUEL COMBUSTION INSTALLATIONS IN THE LISTED ACTIVITIES AND ASSOCIATED MINIMUM EMISSION STANDARDS. https://cer.org.za/wp-content/uploads/2020/05/CER-letter_-Request-for-Reasons_SO2-MES-doubling_3-April-2020.pdf?x21779

Chicago

Centre for Environmental Rights. REQUEST FOR REASONS FOR THE AMENDMENT OF SUBCATEGORY 1.1: SOLID FUEL COMBUSTION INSTALLATIONS IN THE LISTED ACTIVITIES AND ASSOCIATED MINIMUM EMISSION STANDARDS. 2020. https://cer.org.za/wp-content/uploads/2020/05/CER-letter_-Request-for-Reasons_SO2-MES-doubling_3-April-2020.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=REQUEST FOR REASONS FOR THE AMENDMENT OF SUBCATEGORY 1.1: SOLID FUEL COMBUSTION INSTALLATIONS IN THE LISTED ACTIVITIES AND ASSOCIATED MINIMUM EMISSION STANDARDS |date=3 April 2020 |url=https://cer.org.za/wp-content/uploads/2020/05/CER-letter_-Request-for-Reasons_SO2-MES-doubling_3-April-2020.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2020request, author = {{Centre for Environmental Rights}}, title = {{REQUEST FOR REASONS FOR THE AMENDMENT OF SUBCATEGORY 1.1: SOLID FUEL COMBUSTION INSTALLATIONS IN THE LISTED ACTIVITIES AND ASSOCIATED MINIMUM EMISSION STANDARDS}}, publisher = {Centre for Environmental Rights}, year = {2020}, month = apr, url = {https://cer.org.za/wp-content/uploads/2020/05/CER-letter_-Request-for-Reasons_SO2-MES-doubling_3-April-2020.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }