fa35-submission-busa-dated-august-2009-8710f9ea67f6044a.pdf

Business Unity South Africa (BUSA) submitted a statement in August 2009 expressing concerns over proposed minimum emission limits. BUSA argues that the standards are unjustifiably stringent, deviate from previous industry discussions during the SABS process, and fail to account for the operational realities of upset conditions, potentially harming the competitiveness of South African manufacturing and exports.

• BUSA claims the proposed emission limits deviate significantly from previous discussions held during the SABS process. Specifically, BUSA asserts that the Department abandoned the SABS process and failed to incorporate industry concerns, such as the impossibility of applying new plant standards to existing plants without exemptions.
• BUSA argues that the proposed standards are unjustifiably stringent, exceeding equivalent standards in developed countries. This discrepancy is cited as a risk to the competitiveness of manufactured exports to those countries and may lead to high implementation costs without necessarily meeting environmental goals.
• BUSA contends that the proposed regulations fail to account for 'upset conditions' and the diversity of individual sites. BUSA proposes that the management of emissions under these conditions should be handled through site-specific atmospheric emission licences rather than universal requirements.
• BUSA requests that a regulatory impact assessment be conducted before the finalisation of the legislation to avoid negative socio-economic consequences for the manufacturing sector, which is already affected by the global economic recession.

APA

Centre for Environmental Rights (n.d.). fa35-submission-busa-dated-august-2009-8710f9ea67f6044a.pdf. https://cer.org.za/wp-content/uploads/2014/06/FA35-Submission-BUSA-dated-August-2009.pdf?x21779

Chicago

Centre for Environmental Rights. fa35-submission-busa-dated-august-2009-8710f9ea67f6044a.pdf. n.d. https://cer.org.za/wp-content/uploads/2014/06/FA35-Submission-BUSA-dated-August-2009.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=fa35-submission-busa-dated-august-2009-8710f9ea67f6044a.pdf |url=https://cer.org.za/wp-content/uploads/2014/06/FA35-Submission-BUSA-dated-August-2009.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsndfa35submissionbusadatedaugust20098710f9ea67f6044apdf, author = {{Centre for Environmental Rights}}, title = {{fa35-submission-busa-dated-august-2009-8710f9ea67f6044a.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/06/FA35-Submission-BUSA-dated-August-2009.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }