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

The Centre for Environmental Rights (CER), representing groundWork and the Highveld Environmental Justice Network (HEJN), submitted preliminary comments on the Department of Environmental Affairs' (DEA) draft mid-term review (MTR) of the Highveld Priority Area (HPA) Air Quality Management Plan (AQMP). The CER argues that the draft review is outdated, lacks a systematic methodology, and fails to provide sufficient evidence to support its conclusions, ultimately concluding that the HPA's goal of achieving compliance with national ambient air quality standards (NAAQS) has not been met.

• The CER contends that the draft mid-term review (MTR) is fundamentally flawed due to an unsystematic methodology and outdated data. The document was dated December 2015 but only released for comment in February 2017, meaning it excluded 2016 monitoring data and annual emission reports from atmospheric emission licences (AELs) that applied from April 2015.
• Ambient air quality in the Highveld Priority Area (HPA) remains in widespread non-compliance with national ambient air quality standards (NAAQS). The CER asserts that the overall objective of the HPA AQMP is not being met and that there has been no appreciable improvement in air quality since the plan's gazetting.
• The air quality monitoring network in the HPA is described as inadequate and deteriorating. While the number of stations grew from 20 to 31 since 2013, many are non-functional due to resource and capacity constraints. Specifically, the CER notes that monitoring data for the Ekurhuleni Metropolitan Municipality—the most densely populated and industrial area—was omitted from the MTR.
• Industrial and mining sources are identified as the primary contributors to pollution, with industrial sources accounting for approximately 99.57% of SO2 and 95.97% of NOx, while mining is the largest contributor of PM10. The CER argues that industrial interventions have been inadequate and that the MTR fails to provide a credible account of changes in total industrial emissions.
• The CER highlights significant failures in data reporting and transparency. Only 75% of listed activities in the HPA reported emissions to the National Atmospheric Emissions Inventory System (NAEIS). Furthermore, the South African Air Quality Information System (SAAQIS) is functioning sub-optimally due to poor software documentation and failed upgrade attempts.
• Governmental organizational capacity is deemed insufficient to enforce air quality standards. The CER reports that authorities in the Nkangala District Municipality (NDM) and eMalahleni Local Municipality are severely under-capacitated in terms of finances and personnel, leaving officials over-stretched and unable to devote adequate time to 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} }