REPRESENTATIONS ON THE NOTICE OF INTENTION TO AMEND THE LIST OF ACTIVITIES WHICH RESULT IN ATMOSPHERIC EMISISONS WHICH HAVE OR MAY HAVE A SIGNFICANT DETRIMENTAL EFFECT ON THE ENVIRONMENT, INCLUDING HEALTH, SOCIAL CONDITIONS, ECONOMIC CONDITIONS, ECOLOGICAL CONDITIONS OR CULTURAL HERITAGE

The Centre for Environmental Rights, on behalf of the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, supports the elimination of 'rolling postponements' for emission standards but argues that the draft legislation lacks sufficient safeguards. The submission recommends that postponement applications be contingent on ambient air quality compliance, require full public disclosure of decommissioning schedules, and mandate stricter emission standards for facilities seeking once-off suspensions, particularly in air quality priority areas.

• The submission supports the draft amendments that eliminate further opportunities to postpone compliance with existing plant minimum emission standards (MES) and prohibit postponements of new plant MES beyond 31 March 2025.
• The authors argue that the List of Activities should explicitly require that ambient air quality standards in an area are in compliance and will remain so even if a postponement is granted, specifically noting that industries in the Vaal Triangle, Highveld, and Waterberg-Bojanala Priority Areas should not be permitted to apply for postponements.
• The submission demands that all application documents, including 'clear decommissioning schedules' for once-off suspensions, be made publicly available for comment to ensure meaningful participation by interested and affected parties.
• For facilities seeking a once-off suspension, the submission argues that stricter emission standards—informed by a health risk assessment—should be imposed, and that the decommissioning deadline must be clearly set no later than 2030.
• The submission recommends that decisions on postponement or suspension applications be made at least six months before the compliance date to allow industry sufficient time for planning and investment if an application is refused.
• The authors object to the public consultation process, stating that the 30-day window to comment on three major air quality documents simultaneously was insufficient and inconsistent with the Constitution and the National Environmental Management Act, 1998.

APA

Centre for Environmental Rights (2018). REPRESENTATIONS ON THE NOTICE OF INTENTION TO AMEND THE LIST OF ACTIVITIES WHICH RESULT IN ATMOSPHERIC EMISISONS WHICH HAVE OR MAY HAVE A SIGNFICANT DETRIMENTAL EFFECT ON THE ENVIRONMENT, INCLUDING HEALTH, SOCIAL CONDITIONS, ECONOMIC CONDITIONS, ECOLOGICAL CONDITIONS OR CULTURAL HERITAGE. https://cer.org.za/wp-content/uploads/2018/06/CER-submission-on-proposed-amendments-to-MES-postponement-provisions_25-June-2018-1.pdf?x21779

Chicago

Centre for Environmental Rights. REPRESENTATIONS ON THE NOTICE OF INTENTION TO AMEND THE LIST OF ACTIVITIES WHICH RESULT IN ATMOSPHERIC EMISISONS WHICH HAVE OR MAY HAVE A SIGNFICANT DETRIMENTAL EFFECT ON THE ENVIRONMENT, INCLUDING HEALTH, SOCIAL CONDITIONS, ECONOMIC CONDITIONS, ECOLOGICAL CONDITIONS OR CULTURAL HERITAGE. 2018. https://cer.org.za/wp-content/uploads/2018/06/CER-submission-on-proposed-amendments-to-MES-postponement-provisions_25-June-2018-1.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=REPRESENTATIONS ON THE NOTICE OF INTENTION TO AMEND THE LIST OF ACTIVITIES WHICH RESULT IN ATMOSPHERIC EMISISONS WHICH HAVE OR MAY HAVE A SIGNFICANT DETRIMENTAL EFFECT ON THE ENVIRONMENT, INCLUDING HEALTH, SOCIAL CONDITIONS, ECONOMIC CONDITIONS, ECOLOGICAL CONDITIONS OR CULTURAL HERITAGE |date=25 June 2018 |url=https://cer.org.za/wp-content/uploads/2018/06/CER-submission-on-proposed-amendments-to-MES-postponement-provisions_25-June-2018-1.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2018representations, author = {{Centre for Environmental Rights}}, title = {{REPRESENTATIONS ON THE NOTICE OF INTENTION TO AMEND THE LIST OF ACTIVITIES WHICH RESULT IN ATMOSPHERIC EMISISONS WHICH HAVE OR MAY HAVE A SIGNFICANT DETRIMENTAL EFFECT ON THE ENVIRONMENT, INCLUDING HEALTH, SOCIAL CONDITIONS, ECONOMIC CONDITIONS, ECOLOGICAL CONDITIONS OR CULTURAL HERITAGE}}, publisher = {Centre for Environmental Rights}, year = {2018}, month = jun, url = {https://cer.org.za/wp-content/uploads/2018/06/CER-submission-on-proposed-amendments-to-MES-postponement-provisions_25-June-2018-1.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }