EXPERT AFFIDAVIT: PROFESSOR BRETT COHEN

This expert affidavit by Professor Brett Cohen provides a critical appraisal of the climate change impact assessment (CCIA) and the need and desirability analysis for the proposed Lephalale Coal Mines Colliery project. Professor Cohen concludes that the project's climate impacts were not adequately considered in the Environmental Authorisation and that the analysis supporting the mine's necessity is based on outdated policies and lacks sufficient detail regarding alternatives.

• The climate change impacts of the Lephalale Coal Mines Colliery project were not sufficiently addressed in the Environmental Authorisation (EA).
• The need and desirability analysis for the project in the Final Environmental Impact Assessment Report (FEIAR) is deficient because it relies on outdated policies and fails to provide necessary detail to justify the mine given available electricity generation alternatives and uncertain coal markets. Furthermore, the analysis inadequately considers or entirely ignores alternatives, including the 'no-go' option.
• The Climate Change Impact Assessment (CCIA) was a limited desktop study that lacked the comprehensive detail required for a decision of this magnitude. It failed to include essential elements such as a thorough consideration of global climate challenges, local and global policy responses, and estimates for all projected emissions, including indirect and life cycle (Scope 3) emissions.
• The CCIA provided an inadequate overview of the global climate crisis and the scientific consensus established by the IPCC, failing to mention numerous negative impacts such as species extinction, water availability, and extreme weather events.
• Current scientific consensus and international roadmaps indicate that new unabated fossil fuel infrastructure is incompatible with limiting global warming to 1.5°C. The International Energy Agency (IEA) specifically states that achieving net zero by 2050 requires that no new coal mines or mine extensions be approved.
• While South Africa's Integrated Resource Plan (IRP) suggests a continued role for coal based on high efficiency low emission (HELE) technologies, such as Carbon Capture and Storage (CCS), these technologies are often unproven at scale or prohibitively expensive. CCS specifically involves high capital costs—nearly double that of facilities without it—and significant energy penalties.

APA

COHEN, B. (n.d.). EXPERT AFFIDAVIT: PROFESSOR BRETT COHEN. Centre for Environmental Rights. https://cer.org.za/wp-content/uploads/2022/10/Expert-Affidavit-of-Professor-Brett-Cohen.pdf?x21779

Chicago

COHEN, BRETT. EXPERT AFFIDAVIT: PROFESSOR BRETT COHEN. Centre for Environmental Rights, n.d. https://cer.org.za/wp-content/uploads/2022/10/Expert-Affidavit-of-Professor-Brett-Cohen.pdf?x21779.

Wikipedia

{{cite press release |last1=COHEN |first1=BRETT |title=EXPERT AFFIDAVIT: PROFESSOR BRETT COHEN |publisher=Centre for Environmental Rights |url=https://cer.org.za/wp-content/uploads/2022/10/Expert-Affidavit-of-Professor-Brett-Cohen.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{cohenndexpert, author = {COHEN, BRETT}, title = {{EXPERT AFFIDAVIT: PROFESSOR BRETT COHEN}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2022/10/Expert-Affidavit-of-Professor-Brett-Cohen.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }