COMMENTS ON THE DRAFT STRATEGY TO ADDRESS AIR POLLUTION IN DENSE LOW INCOME SETTLEMENTS

The Centre for Environmental Rights (CER), representing several environmental justice organisations, submitted comments on the 2016 Draft Strategy to Address Air Pollution in Dense Low Income Settlements. While welcoming the document, the CER argues that it lacks measurable plans, adequate baseline data, and a strategy for community consultation to effectively address the health impacts of domestic fuel burning in South Africa.

• The CER argues that the draft Strategy lacks adequate, measurable, and progressive plans to address the harmful impacts of domestic fuel burning, despite providing a detailed description of the issues.
• The CER contends that the right to an environment not harmful to health or well-being, as established in Section 24 of the Constitution, is universal and should not be subject to 'progressive realisation' or the availability of resources.
• The CER criticizes the draft Strategy's definition of 'low-income settlements' as being based on emissions from dirty fuels rather than actual income levels.
• The document highlights a critical lack of current baseline data in the draft Strategy, noting that the 10 studies cited were all published five or more years prior to 2016, and that specific impacts of indoor pollution on outdoor air quality in critical areas are not quantified.
• The CER identifies a significant omission of a consultation strategy for affected communities, asserting that interventions developed without the involvement of those most impacted are unlikely to succeed.
• The CER expresses strong opposition to the use of air quality 'offsets' mentioned in the draft Strategy, arguing that such measures are corporate social responsibility actions and cannot replace compliance with legislated air quality standards.
• The CER recommends that the draft Strategy be amended to include a formal review and update process every five years, incorporating public participation.

APA

Centre for Environmental Rights (2016). COMMENTS ON THE DRAFT STRATEGY TO ADDRESS AIR POLLUTION IN DENSE LOW INCOME SETTLEMENTS. https://cer.org.za/wp-content/uploads/2016/08/CER-Submissions-on-the-Draft-Strategy-to-Address-Air-Pollution-in-Dense-Low-Income-Settlements-29-August-2016.pdf?x21779

Chicago

Centre for Environmental Rights. COMMENTS ON THE DRAFT STRATEGY TO ADDRESS AIR POLLUTION IN DENSE LOW INCOME SETTLEMENTS. 2016. https://cer.org.za/wp-content/uploads/2016/08/CER-Submissions-on-the-Draft-Strategy-to-Address-Air-Pollution-in-Dense-Low-Income-Settlements-29-August-2016.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=COMMENTS ON THE DRAFT STRATEGY TO ADDRESS AIR POLLUTION IN DENSE LOW INCOME SETTLEMENTS |date=29 August 2016 |url=https://cer.org.za/wp-content/uploads/2016/08/CER-Submissions-on-the-Draft-Strategy-to-Address-Air-Pollution-in-Dense-Low-Income-Settlements-29-August-2016.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2016comments, author = {{Centre for Environmental Rights}}, title = {{COMMENTS ON THE DRAFT STRATEGY TO ADDRESS AIR POLLUTION IN DENSE LOW INCOME SETTLEMENTS}}, publisher = {Centre for Environmental Rights}, year = {2016}, month = aug, url = {https://cer.org.za/wp-content/uploads/2016/08/CER-Submissions-on-the-Draft-Strategy-to-Address-Air-Pollution-in-Dense-Low-Income-Settlements-29-August-2016.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }