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This document contains the heads of argument filed by Lephalale Coal Mine (Pty) Ltd (LCM) in the High Court of South Africa. LCM responds to a review application by Earthlife Africa seeking to set aside environmental authorisations for a proposed coal mine in Limpopo Province. LCM concedes that its original climate change impact assessment was insufficient and agrees that the related decision should be reviewed and set aside, but opposes all other grounds of review regarding air quality, health impacts, cumulative impacts, and public consultation.

This document contains the heads of argument submitted by the First and Second Respondents (Groundwork Trust and Vukani Environmental Justice Alliance Movement in Action) to the Supreme Court of Appeal of South Africa. The respondents argue that the Minister of Environmental Affairs has a legal duty under section 20 of the National Environmental Management: Air Quality Act and section 7(2) of the Constitution to promulgate regulations to implement and enforce the Highveld Plan. They seek to uphold a High Court judgment that declared the air quality in the Highveld Priority Area a breach of constitutional rights and ordered the Minister to produce enforcement regulations within 12 months.

This document contains the Short Heads of Argument filed on 11 March 2021 by the First Respondent, Uthaka Energy (Pty) Ltd, in the High Court of South Africa (Gauteng Division, Pretoria). Uthaka argues against an urgent application for an interim interdict brought by the Mining and Environmental Justice Community Network of South Africa and others, which seeks to stop the commencement of the Yzermyn Underground Coal-mining Project. Uthaka contends that it possesses all necessary statutory authorisations and that the application lacks urgency, a prima facie right, and a reasonable apprehension of irreparable harm.

This document consists of a practice note and heads of argument filed by Tendele Coal Mining (Pty) Ltd in the Supreme Court of Appeal of South Africa. Tendele is responding to an appeal by the Global Environmental Trust and others who seek an interdict to close the Somkhele Coal Mine, alleging that the mine operates without necessary environmental, land use, waste management, and heritage authorizations.

This document contains the heads of argument submitted by ACWA Power to the Appeal Authority of the Nkangala District Municipality. ACWA argues that an appeal brought by the non-profit organization GroundWork against the transfer of a Provisional Atmospheric Emission Licence (PAEL) should be dismissed because GroundWork, as a third party, lacks the legal standing to appeal under section 62 of the Local Government Municipal Systems Act 32 of 2000.

This amicus curiae brief, submitted by the Center for International Environmental Law (CIEL) and other organizations, argues that the International Organizations Immunities Act (IOIA) should be interpreted under a "restrictive theory" of immunity. The brief contends that international organizations, such as the International Finance Corporation (IFC), should be immune from suits relating to governmental acts but not from those relating to commercial activities, aligning the IOIA with the Foreign Sovereign Immunities Act (FSIA).

This document contains the applicants' heads of argument in a legal application to review and set aside decisions made by the Minister of Environmental Affairs and the Minister of Mineral Resources to grant Atha-Africa Ventures (Pty) Ltd permission to conduct commercial coal mining in the Mabola Protected Environment (MPE) in Mpumalanga, South Africa.

This amicus curiae brief, submitted by the Center for International Environmental Law (CIEL) on behalf of members of the Mesa Nacional Frente a la Minería Metálica de El Salvador, argues that El Salvador's regulatory measures regarding the 'El Dorado' mining project are consistent with international human rights and environmental obligations. The document contends that the state must protect citizens from the risks of extractive industries, particularly in water-scarce and densely populated areas, and that public interest is defined through environmental democracy and the rights of access to information and participation.

This document contains the heads of argument submitted by the MEC and the Chief Director of the North West Provincial Government (the 1st and 2nd Respondents) in an appeal before the Supreme Court of Appeal of South Africa. The appeal challenges an ex post facto environmental authorization granted under section 24G of the National Environmental Management Act (NEMA) for the Kgaswane Country Lodge, located in the Magaliesberg Protected Environment. The respondents argue that the appellant's request for the demolition of the lodge is disproportionate and that the review application became academic after the appellant failed to obtain an urgent interdict to stop construction.

This document contains the heads of argument submitted by the Fourth Respondent (the Minister of Local Government, Environmental Affairs and Development Planning, Western Cape Province) to the Supreme Court of Appeal of South Africa. The legal dispute centers on whether mining permits or rights granted under the Mineral and Petroleum Resources Development Act (MPRDA) exempt a holder from obtaining land-use authorisations under the Land Use Planning Ordinance (LUPO) and environmental authorisations under the National Environmental Management Act (NEMA). The Fourth Respondent argues that these regulatory regimes are concurrent and that a mining right does not override municipal zoning or national environmental requirements.

The Centre for Environmental Rights (CER), representing 13 NGOs and CSOs, wrote to the Chief Executive of the Chamber of Mines to defend a request made to the Minister of Mineral Resources. The CER argues that existing statutory tools are insufficient to protect areas of critical biodiversity and hydrological value from mining, and therefore urges the Minister to use her discretion under Section 49 of the Minerals and Petroleum Resources Development Act (MPRDA) to declare certain 'no-go areas'.

This amicus curiae submission, filed by a coalition of legal and environmental organizations, argues that the investor Biwater Gauff (Tanzania) Limited failed to meet its professional and legal responsibilities during the privatization of water services in Dar es Salaam. The submission contends that the investor's failure to conduct proper due diligence and its potential use of a 'renegotiation strategy'—bidding low to win a contract with the intent to renegotiate terms later—should preclude it from seeking compensation for the contract's termination by the Government of Tanzania.

This amicus curiae brief submitted to the WTO Panel argues that Brazil's import ban on retreaded tires is justified under GATT Article XX. The document contends that a life-cycle approach to product analysis reveals that importing retreaded tires increases waste and public health risks in developing countries, and that such measures are supported by multilateral environmental agreements, human rights law, and the international environmental law principle of prevention.

This joint post-hearing submission by four amici (IISD, CBE, Bluewater Network, and CIEL) argues that the tribunal in the Methanex v. United States arbitration should recognize that bona fide environmental protection measures are non-expropriatory under international law, similar to public health measures.

This document is a submission by non-disputing parties (Bluewater Network, Communities for a Better Environment, and the Center for International Environmental Law) to an arbitration tribunal regarding a dispute between Methanex Corporation and the United States. The submission argues that California's ban on the gasoline additive MTBE was a legitimate exercise of government power to protect public health and the environment, and should therefore be granted substantial deference under NAFTA and international law.

This amicus brief, submitted by the Center for International Environmental Law and other organizations, argues that United States import prohibitions on shrimp harvested without turtle excluder devices (TEDs) are consistent with WTO rules. The brief contends that these measures are justified under GATT Article XX as necessary for the conservation of endangered sea turtles, a goal supported by international environmental law and the principles of sustainable development.

This briefing consists of the Practice Note and Heads of Argument filed by the Centre for Environmental Rights (CER) as an amicus curiae in the Supreme Court of Appeal case Global Environmental Trust & 2 Others vs Tendele Coal Mining (Pty) Ltd & 8 Others. The CER argues that mining operations require both a mining right under the Mineral and Petroleum Resources Development Act (MPRDA) and a separate environmental authorisation under the National Environmental Management Act (NEMA), challenging a lower court's ruling that an approved Environmental Management Plan (EMP) under the MPRDA suffices as environmental authorisation.

This document consists of the heads of argument filed on 17 June 2020 by four applicants (including the Mpukunyoni Traditional Council and labor unions) seeking admission as amicus curiae in an appeal before the Supreme Court of Appeal of South Africa. The applicants argue against a proposed interim interdict that would stop the mining operations of Tendele Coal Mining (Pty) Ltd, asserting that such a closure would cause disastrous socio-economic harm to the local community and the South African ferrochrome industry.

This document consists of the heads of argument filed by Tendele Coal Mining (Pty) Limited (the First Respondent) in the Supreme Court of Appeal of South Africa. The filing is a response to arguments submitted by an amicus curiae (the Centre for Environmental Rights) regarding whether mining operations commencing before 8 December 2014 required both a mining right under the Mineral and Petroleum Resources Development Act (MPRDA) and a separate environmental authorisation under the National Environmental Management Act (NEMA).

This document consists of the practice note, chronology, and heads of argument filed by Arcelormittal South Africa Ltd (AMSA) in the Supreme Court of Appeal of South Africa. AMSA is appealing a High Court judgment that ordered it to disclose environmental records to the Vaal Environmental Justice Alliance (VEJA) under the Promotion of Access to Information Act 2 of 2000 (PAIA). AMSA argues that VEJA failed to meet the 'need to know' threshold required for requests to private bodies and that there is no legal right for a private NGO to act as a regulatory 'watch-dog' to monitor a private company's environmental compliance.