PRELIMINARY COMMENTS ON THE DRAFT MID-TERM REVIEW OF THE HIGHVELD PRIORITY AREA AIR QUALITY MANAGEMENT PLAN

The Centre for Environmental Rights (CER) argues that the draft mid-term review (MTR) of the Highveld Priority Area (HPA) Air Quality Management Plan (AQMP) is methodologically flawed, outdated, and fails to demonstrate progress toward its goals. The CER highlights widespread non-compliance with national ambient air quality standards (NAAQS), a deteriorating monitoring network, and significant data gaps in industrial emissions reporting. It specifically criticizes the lack of functional monitoring stations and the failure of key industrial facilities to reduce emissions, concluding that the overall objective of achieving NAAQS compliance in the HPA is not being met.

• The draft mid-term review (MTR) is criticized for lacking a systematic approach and using outdated data, as it was dated December 2015 but only released for comment in February 2017, thereby omitting 2016 monitoring data and recent annual emission reports.
• Ambient air quality in the Highveld Priority Area (HPA) remains in widespread non-compliance with national ambient air quality standards (NAAQS), and the CER asserts that the overall objective of the AQMP is not being met.
• The air quality monitoring network in the HPA has deteriorated; while the number of stations grew from 20 to 31 since 2013, many are non-functional due to resource and capacity constraints.
• Industrial sources are identified as the primary contributors to SO2 and NOx emissions in the HPA, accounting for approximately 99.57% of SO2 and 95.97% of NOx, yet industrial interventions have had no meaningful impact on air pollution.
• The South African Air Quality Information System (SAAQIS) is functioning sub-optimally due to poor software documentation and failed upgrade attempts, hindering public access to air quality information.
• Local government authorities in the Nkangala District Municipality and eMalahleni Local Municipality are severely under-capacitated in terms of finances and personnel to effectively manage air quality compliance and enforcement.

APA

Centre for Environmental Rights (2017). PRELIMINARY COMMENTS ON THE DRAFT MID-TERM REVIEW OF THE HIGHVELD PRIORITY AREA AIR QUALITY MANAGEMENT PLAN. https://cer.org.za/wp-content/uploads/2016/07/CER-preliminary-comments-on-mid-term-review_23-March-2017_final-1.pdf?x21779

Chicago

Centre for Environmental Rights. PRELIMINARY COMMENTS ON THE DRAFT MID-TERM REVIEW OF THE HIGHVELD PRIORITY AREA AIR QUALITY MANAGEMENT PLAN. 2017. https://cer.org.za/wp-content/uploads/2016/07/CER-preliminary-comments-on-mid-term-review_23-March-2017_final-1.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=PRELIMINARY COMMENTS ON THE DRAFT MID-TERM REVIEW OF THE HIGHVELD PRIORITY AREA AIR QUALITY MANAGEMENT PLAN |date=23 March 2017 |url=https://cer.org.za/wp-content/uploads/2016/07/CER-preliminary-comments-on-mid-term-review_23-March-2017_final-1.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2017preliminary, author = {{Centre for Environmental Rights}}, title = {{PRELIMINARY COMMENTS ON THE DRAFT MID-TERM REVIEW OF THE HIGHVELD PRIORITY AREA AIR QUALITY MANAGEMENT PLAN}}, publisher = {Centre for Environmental Rights}, year = {2017}, month = mar, url = {https://cer.org.za/wp-content/uploads/2016/07/CER-preliminary-comments-on-mid-term-review_23-March-2017_final-1.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }