PROVISIONAL SUBMISSIONS REGARDING THE REVIEW OF THE 2012 NATIONAL FRAMEWORK FOR AIR QUALITY MANAGEMENT IN THE REPUBLIC OF SOUTH AFRICA

The Centre for Environmental Rights (CER), representing several environmental justice organisations, submitted provisional comments on June 29, 2018, regarding the Department of Environmental Affairs' (DEA) proposed amendments to the 2012 National Framework for Air Quality Management in South Africa. The CER argues that the public consultation process was inadequate and that the draft Framework fails to address systemic failures in air quality monitoring, enforcement, and the achievement of previous targets.

• The CER contends that the public consultation process for the 2018 draft Framework was unfair and unreasonable due to a short 30-day comment period for three interrelated documents and a failure to hold meetings in priority areas most impacted by pollution.
• The document asserts that South Africa's National Ambient Air Quality Standards (NAAQS) and Minimum Emission Standards (MES) are too weak and are outdated compared to World Health Organisation (WHO) guidelines, requiring urgent review.
• The CER reports that major polluters Eskom and Sasol have obtained widespread postponements for MES compliance and that Eskom continues to fail to comply even with the more lax standards in its atmospheric emission licences (AELs) without facing enforcement action.
• The draft Framework is criticised for lacking a comprehensive progress review of the 2007 and 2012 Frameworks, often extending expired deadlines or deleting targets without explaining previous failures.
• The CER objects to proposed changes in the draft Framework that would weaken the requirements for MES postponement applications, specifically the removal of requirements to prove that emissions are not causing adverse environmental impacts.
• The submission highlights significant deficiencies in the South African Air Quality Information System (SAAQIS), noting that the new website is a 'shell' lacking critical data, media libraries, and a functional learners' centre.
• The CER argues that greenhouse gas (GHG) reporting is undermined by allowing aggregated company-level reporting instead of mandatory facility-level reporting, which prevents accurate monitoring of emission sources.
• The document notes a critical lack of capacity at the local government level, stating that many municipalities lack the skilled staff and financial resources to implement Air Quality Management Plans (AQMPs) or enforce the Air Quality Act (AQA).
• The CER expresses concern that the government intends to build new coal-fired power stations (such as Thabametsi and Khanyisa) in priority areas where air quality is already poor or deteriorating.

APA

Centre for Environmental Rights (2018). PROVISIONAL SUBMISSIONS REGARDING THE REVIEW OF THE 2012 NATIONAL FRAMEWORK FOR AIR QUALITY MANAGEMENT IN THE REPUBLIC OF SOUTH AFRICA. https://cer.org.za/wp-content/uploads/2018/07/CER-submissions-on-the-draft-amendments-to-the-Framework-for-AQM_29-June-2018.pdf?x21779

Chicago

Centre for Environmental Rights. PROVISIONAL SUBMISSIONS REGARDING THE REVIEW OF THE 2012 NATIONAL FRAMEWORK FOR AIR QUALITY MANAGEMENT IN THE REPUBLIC OF SOUTH AFRICA. 2018. https://cer.org.za/wp-content/uploads/2018/07/CER-submissions-on-the-draft-amendments-to-the-Framework-for-AQM_29-June-2018.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=PROVISIONAL SUBMISSIONS REGARDING THE REVIEW OF THE 2012 NATIONAL FRAMEWORK FOR AIR QUALITY MANAGEMENT IN THE REPUBLIC OF SOUTH AFRICA |date=29 June 2018 |url=https://cer.org.za/wp-content/uploads/2018/07/CER-submissions-on-the-draft-amendments-to-the-Framework-for-AQM_29-June-2018.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2018provisional, author = {{Centre for Environmental Rights}}, title = {{PROVISIONAL SUBMISSIONS REGARDING THE REVIEW OF THE 2012 NATIONAL FRAMEWORK FOR AIR QUALITY MANAGEMENT IN THE REPUBLIC OF SOUTH AFRICA}}, publisher = {Centre for Environmental Rights}, year = {2018}, month = jun, url = {https://cer.org.za/wp-content/uploads/2018/07/CER-submissions-on-the-draft-amendments-to-the-Framework-for-AQM_29-June-2018.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }