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, representing the Life After Coal Campaign, submitted representations to the South African Department of Environmental Affairs supporting the removal of 'rolling postponements' for minimum emission standards. The CER argues for stricter health-based emission limits for facilities seeking suspensions, mandatory public disclosure of decommissioning schedules, and a more robust public participation process, while highlighting that current national air quality standards are inadequate compared to WHO guidelines.

• The Life After Coal Campaign supports the draft amendments to the List of Activities that eliminate further opportunities to postpone compliance with existing plant minimum emission standards (MES) and end 'rolling postponements'—the practice of re-applying for postponements every five years until decommissioning.
• The CER argues that the requirements of the 2012 National Framework for Air Quality Management must be explicitly incorporated into the List of Activities. Specifically, they assert that postponements should not be granted if ambient air quality standards are not in compliance, particularly in the Vaal Triangle, Highveld, and Waterberg-Bojanala Priority Areas.
• The submission demands that all application documents for postponements or suspensions, including 'clear decommissioning schedules', be made available for public comment to ensure meaningful participation by interested and affected parties.
• The CER contends that South Africa's National Ambient Air Quality Standards (NAAQS) and MES are weak and require updating every five years to better protect human health, noting that current standards are weaker than the World Health Organisation's 2005 guidelines.
• For facilities granted a once-off suspension of compliance, the CER proposes that they be required to meet stricter emission standards than existing plant standards, informed by a health risk assessment, with a final decommissioning deadline no later than 2030.
• The CER 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 Life After Coal Campaign objects 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 National Environmental Management Act and the Constitution.

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} }