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This document is a responding statement submitted by Jones & Wagener (on behalf of Kuyasa Mining and KiPower) to the Department of Environmental Affairs (DEA). It addresses an appeal by the Centre for Environmental Rights (CER) against the granting of an integrated environmental authorisation for a 600MW coal-fired independent power plant near Delmas, Mpumalanga. The statement denies allegations that the project violates NEMA principles or environmental laws, arguing that the project aligns with the Department of Energy's Integrated Resource Plan (IRP) and employs Circulating Fluidised Bed (CFB) technology to mitigate pollutants.

The document is a formal comment letter from a coalition of environmental groups regarding the proposed Stream Protection Rule. The authors argue that the rule fails to adequately protect stream channels from direct damage, particularly in Central Appalachia, and relies on unproven stream restoration techniques. They contend that OSMRE ignored critical factors in its analysis, including the structural decline of coal demand, the net economic drain of mining on the region, and severe public health impacts. The coalition urges the agency to retain the 1983 stream buffer zone, strengthen water quality standards, and incorporate the social cost of carbon into its environmental impact assessments.

The 'Environmental Impact Assessment Guideline for Renewable Energy Projects' outlines the regulatory framework and procedural requirements for deploying renewable energy technologies in South Africa. It details the environmental impacts of various technologies—including wind, solar, biomass, and hydropower—and maps these to the specific national legislation and authorisations required under the National Environmental Management Act (NEMA) and other sectoral laws. The guide provides a structured approach to the Basic Assessment (BA) and Scoping and Environmental Impact Reporting (S&EIR) processes, including timeframes, stakeholder roles, and mitigation strategies to ensure sustainable development.

The report argues that the proposed Oakland Bulk and Oversized Terminal (OBOT) poses significant risks to public health, water security, and local ecosystems, particularly if used to export coal. The author highlights that current design plans are conceptual and lack enforceable controls for dust and emissions. Key concerns include the consumption of 79.2 million gallons of water annually for dust control during a record drought, the release of up to 18,300 tons of coal dust per year within California from uncovered rail cars, and increased cancer risks from diesel particulate matter in West Oakland. Additionally, the report notes that the project's scale would cause significant traffic congestion at 55 at-grade rail crossings and create substantial noise pollution. The author concludes that these impacts were not addressed in the project's CEQA review.

Earthjustice, representing a coalition of environmental and community groups, urges the City of Oakland to reject the development of a coal export terminal at the former Oakland Army Base. The letter asserts that the project would disproportionately burden the low-income, predominantly African American community of West Oakland with particulate matter and diesel pollution, while violating California's greenhouse gas reduction goals. It argues that proposed mitigations, such as covered rail cars, are ineffective and that the project is an economic risk due to declining global coal demand. Finally, the document claims the project lacks necessary environmental review under CEQA and NEPA and that the City possesses the legal authority to ban the terminal to protect public health.

The report argues that the pharmaceutical industry is fueling the antimicrobial resistance (AMR) crisis through the unmonitored dumping of antibiotic-laden waste into the environment during the production of active pharmaceutical ingredients (APIs). It highlights a 'three-tier chain' where raw materials from China are processed in India and then sold to global markets. The document identifies specific polluting factories in China—including NCPC, CSPC/Inner Mongolia Changsheng, and Sinopharm—and links them to major companies such as Pfizer, Teva, and McKesson. It concludes that current Good Manufacturing Practices (GMP) are insufficient because they lack environmental criteria, and calls for greater supply chain transparency and the integration of environmental protection into global pharmaceutical standards.

The report argues that the discharge of antibiotic active pharmaceutical ingredients (APIs) into the environment during production, primarily in China and India, accelerates the development of superbugs. It highlights a lack of transparency in pharmaceutical supply chains, linking major global companies like Pfizer, Teva, and McKesson to polluting factories. The document calls for the integration of environmental protection criteria into Good Manufacturing Practices (GMP) and greater corporate transparency to mitigate this global health threat.

The Centre for Environmental Rights (CER), representing groundWork, Earthlife Africa Johannesburg, and the Highveld Environmental Justice Network, filed an appeal on May 20, 2015, against the atmospheric emission licence (AEL) issued to Eskom's Camden Power Station. The appeal argues that the Gert Sibande District Municipality failed to consider the severe health impacts and poor air quality of the Highveld Priority Area (HPA) when granting emission limit postponements that allow pollutants to exceed national minimum emission standards (MES).

This document is a formal appeal submitted by the Centre for Environmental Rights (CER) on behalf of groundWork, Earthlife Africa Johannesburg, and the Highveld Environmental Justice Network. The appeal challenges the variation of the Atmospheric Emission Licence (AEL) for Eskom's Hendrina Power Station, issued by the Nkangala District Municipality on 31 March 2015. The appellants argue that the AEL improperly incorporates postponements of Minimum Emission Standards (MES) granted by the National Air Quality Officer, thereby permitting pollution levels that exceed national standards in a declared priority area with already compromised air quality.

This document is a formal notice of appeal filed on 30 March 2015 by eight environmental organisations, represented by the Centre for Environmental Rights, against the granting of mining right MP30/5/1/2/2/1/0069MR to Atha-Africa Ventures (Pty) Ltd (AAV). The appeal seeks to set aside the right and suspend its operation, arguing that the proposed Yzermyn underground coal mine is located in the Mabola Protected Environment and the Wakkerstroom Wetlands Area, regions of irreplaceable biodiversity and critical hydrological importance.

The document argues that the Town of Tusayan's application for special use authorizations on Kaibab National Forest land is not in the public interest because it enables a massive resort development by Gruppo Stilo USA. The authors contend that the project threatens the Redwall-Muav regional aquifer, which supports critical springs in Grand Canyon National Park and the water supply of the Havasupai Tribe. They further argue that the development would cause light and noise pollution, overwhelm park infrastructure, and harm wildlife habitats, including elk calving grounds and antelope fawning areas. The letter urges the Forest Service to deny the application before initiating a National Environmental Policy Act (NEPA) process.

Tight oil, also known as shale oil, is extracted from impermeable rock using hydraulic fracturing, a process that is more energy-intensive and polluting than conventional drilling. In the United States, tight oil's share of domestic production rose from 23 percent in 2011 to 45 percent in 2013. Key environmental concerns include flaring of associated natural gas, fugitive methane emissions, and pollution of water, air, and noise. The document argues that transitioning to cleaner transportation technologies and improving extraction infrastructure can reduce the reliance on and emissions from tight oil.

The report argues that the Mabola Protected Environment (MPE) was correctly proclaimed due to its high biodiversity and hydrological importance. It concludes that de-proclaiming the MPE to allow the Yzermyn coal mine would set a dangerous precedent, risk irreplaceable ecosystems, and contradict South Africa's climate change goals. While the mine's current underground plan has moderate short-term impacts, the report warns of long-term risks including acid mine decant and permanent loss of critical water-producing wetlands.

The document asserts that the fuel economy of U.S. tractor-trailers has remained stagnant since the 1970s, averaging around 6 miles per gallon. It argues that implementing stronger standards could improve the efficiency of new trucks by 40 percent by 2025, raising average fuel economy from 6.3 mpg to 10.7 mpg. Such improvements would reduce petroleum consumption by over 570,000 barrels of oil per day and prevent over 110 million metric tons of global warming emissions annually. Economically, the report claims these standards would save truck owners $30,000 in fuel costs per vehicle annually and could reduce freight rates by nearly 10 percent, potentially providing households with $135 in annual savings.

The report examines the transition of the U.S. power sector from coal to natural gas, highlighting that while this shift provides immediate reductions in some pollutants, it creates long-term risks including price volatility, methane leakage, and stranded assets. Through modeling three scenarios—Business as Usual, a Carbon Standard, and a Carbon Standard plus Renewables and Efficiency Policies—the authors find that a diversified energy mix is the most economically and environmentally sound approach. The 'Carbon Standard plus Renewables and Efficiency Policies' scenario is projected to reduce power plant carbon emissions by 70% below 2005 levels by 2040 and generate net societal benefits of nearly $170 billion by that year. The report recommends strengthening the EPA's Clean Power Plan, implementing federal renewable electricity and energy efficiency standards, and increasing regulations on fugitive methane emissions.

The document argues that the Port of Seattle improperly used a SEPA categorical exemption to avoid environmental review for an interim lease of Terminal 5 to Foss Maritime. The authors contend that using the terminal as a home port for Shell's Arctic drilling fleet—including vessels like the Noble Discoverer—would change the site's use from a container terminal to a shipyard, risking toxic runoff and water pollution that could harm threatened Puget Sound Chinook salmon. The letter further highlights Shell's poor safety record in the Arctic and the broader climate implications of Arctic oil exploration.

The Union of Concerned Scientists argues that increasing Minnesota's renewable energy standard to 40 percent by 2030 would drive over $6 billion in new capital investments and reduce reliance on imported electricity without significantly impacting retail rates. The analysis indicates that such a policy would increase wind capacity to nearly 6,000 MW and utility-scale solar to over 600 MW by 2030. While a strengthened RES helps position the state to comply with the EPA's Clean Power Plan, the report notes that coal would still provide 38 percent of electricity in 2030 without additional policy actions. The authors recommend combining the strengthened RES with an increased energy efficiency standard of 2 percent annually by 2020.

The paper examines the conflict between bioenergy production and the global need for food, feed, and carbon sequestration. It argues that dedicated land use for bioenergy—including crop-based biofuels and cellulosic energy crops—exacerbates a projected 70 percent crop calorie gap by 2050. The authors contend that bioenergy is an inefficient use of solar radiation compared to solar photovoltaics (PV), which can produce over 100 times more energy per hectare. Furthermore, the document identifies a systemic 'double counting' error in greenhouse gas accounting that erroneously treats biomass as carbon-free. It recommends phasing out subsidies and mandates for land-dedicated bioenergy while prioritizing 'additional' biomass sources such as municipal waste and specific residues.

The evaluation finds that Joint Implementation (JI) likely increased global GHG emissions by approximately 600 million tCO2e because many projects lacked additionality and were hosted by countries with significant allowance surpluses. The report highlights systemic failures in auditing, particularly under Track 1, and notes that 80% of issued ERUs came from project types with low or questionable environmental integrity. It recommends international oversight, standardized methodologies, and the prohibition of retroactive crediting for future mechanisms.

The document highlights the link between oil and gas emissions and ground-level ozone, asserting that methane regulations provide significant co-benefits by reducing VOCs more effectively than direct VOC regulations or previous EPA programs. It notes a high overlap between oil and gas production areas and regions exceeding proposed ozone standards, particularly west of the Mississippi River.