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OBJECTIONS: ARCELORMITTAL SOUTH AFRICA APPLICATION FOR ALTERNATIVE SO2 MINIMUM EMISSION STANDARDS LIMIT AT DIRECT REDUCTION KILNS, ARCELORMITTAL VANDERBIJLPARK WORKS, GAUTENG PROVINCE
The Centre for Environmental Rights, acting for the Vaal Environmental Justice Alliance (VEJA), submitted formal objections to ArcelorMittal South Africa's (AMSA) application for an alternative SO2 emission limit at its Vanderbijlpark Works. The objections argue that granting a limit of 1,500 mg/Nm³—three times the legal standard of 500 mg/Nm³—would violate constitutional rights to a healthy environment, ignore the conversion of SO2 into dangerous particulate matter (PM), and prioritize corporate cost-savings over public health in a known pollution hotspot.
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Document type: Statement
OBJECTIONS TO THE SCOPING REPORT FOR THE MOTUOANE PRODUCTION RIGHT APPLICATION, WITHIN VARIOUS FARMS IN MATJHABENG AND MASILONYA LOCAL MUNICIPALITIES, LEJWELEPUTSWA DISTRICT MUNICIPALITIES, FREE STATE PROVINCE, SOUTH AFRICA
The Centre for Environmental Rights and Natural Justice, representing several community and environmental networks, submitted formal objections to the Scoping Report for the Motuoane Production Right application. The project proposes hydrocarbon exploration and extraction over approximately 14,400 hectares in the Free State Province, involving up to 43 production wells and associated infrastructure. The objectors argue that the Scoping Report is deficient in its assessments of air quality, climate change, hydrogeology, and social impacts, and that the public participation process was not meaningful.
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Document type: Statement
OBJECTIONS TO THE MOTUOANE EXPLORATION RIGHT 386 APPLICATION, WITHIN VARIOUS FARMS IN MATJHABENG AND MOQHAKA LOCAL MUNICIPALITIES, LEJWELEPUTSWA AND FEZILE DABI DISTRICT MUNICIPALITIES, FREE STATE PROVINCE, SOUTH AFRICA
The Centre for Environmental Rights, on behalf of MACUA and MEJCON-SA and jointly with Natural Justice, submitted formal objections to the Motuoane Exploration Right 386 application. The submission argues that the project's scoping report is deficient in its assessment of climate change, air quality, and groundwater impacts, and that the public participation process was exclusionary and legally inadequate.
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Document type: Statement
OBJECTION TO TETRA4’s WATER USE LICENCE AMENDMENT APPLICATION FOR CLUSTER 2 EXPANSION
The Centre for Environmental Rights, representing MEJCON-SA and MACUA, submitted a formal objection on May 9, 2023, against Tetra4 (Pty) LTD's application to amend its Water Use Licence (WUL) for the Cluster 2 expansion of gas and helium production near Virginia, Free State. The objection argues that the Integrated Water and Waste Management Plan (IWWMP) fails to adequately assess risks of groundwater contamination, radioactive waste, municipal water stress, and the compounding effects of climate change on a region critical for South African food security.
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Document type: Statement
PROPOSED RELEASE OF UNABATED SULPHUR DIOXIDE EMISSIONS FROM KUSILE COAL-FIRED POWER STATION
The Centre for Environmental Rights (CER), on behalf of the Life After Coal Campaign, submitted a formal objection to the South African government regarding Eskom's proposal to use temporary bypass stacks at the Kusile coal-fired power station. This proposal would allow units 1-3 to operate without flue-gas desulphurisation (FGD) pollution abatement equipment following a flue duct collapse in October 2022. The CER argues that the bypass would cause significant health damage and constitutional violations, suggesting instead that funds be redirected toward solar PV and wind energy to accelerate the coal phase-out.
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Document type: Statement
COMMENT ON THE PROPOSED CONCURRENCE WITH THE MINISTERIAL DETERMINATION ON THE PROCUREMENT OF NEW GENERATION CAPACITY OF 3000 MW FROM GAS
A joint submission by the Centre for Environmental Rights (CER), groundWork Trust, South Durban Community Environmental Alliance (SDCEA), and Natural Justice objecting to a proposed Ministerial Determination for the procurement of 3,000 MW of gas-to-power capacity in South Africa. The submission argues that the determination is legally flawed, procedurally unfair, and environmentally and economically irrational.
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Document type: Statement
OBJECTIONS TO THE WATER USE LICENCE APPLICATION FOR THE PROPOSED MOKOLO CROCODILE RIVER (WEST) WATER AUGMENTATION PROJECT PHASE2A (MCWAP-2A)
The Centre for Environmental Rights (CER), on behalf of Earthlife Africa and groundWork, submitted formal objections on 14 June 2022 to the Integrated Water Use Licence Application (IWULA) for Phase 2A of the Mokolo Crocodile River (West) Water Augmentation Project (MCWAP-2A). The CER argues that the project is an unnecessary inter-basin transfer designed to support coal expansion, which contradicts South Africa's climate commitments and poses severe risks to aquatic ecosystems and local communities.
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Document type: Statement
OBJECTIONS TO THE SEPTEMBER 2021 “FINAL” ENVIRONMENTAL IMPACT ASSESSMENT REPORT [REVISION 03] OF THE PROPOSED MUSINA-MAKHADO SPECIAL ECONOMIC ZONE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE (LIM/EIA/0000793/2019)
The Centre for Environmental Rights (CER), representing groundWork, Earthlife Africa, and the Mining and Environmental Justice Community Network of South Africa, submitted formal objections to the September 2021 Final Environmental Impact Assessment Report (FEIR) for the proposed Musina-Makhado Special Economic Zone (MMSEZ). The CER argues that the EIA process is unlawful, procedurally irregular, and based on inadequate specialist assessments, concluding that the project's negative impacts on climate, water, and health outweigh its projected benefits.
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Document type: Statement
OBJECTION TO THE NIFPP WATER USE LICENCE APPLICATION
The Centre for Environmental Rights, acting for groundWork, submitted a formal objection on 18 June 2021 to the Water Use Licence (WUL) application for the Nseleni Independent Floating Power Plant (NIFPP) at the Port of Richards Bay. The objection argues that the 12-page application is 'woefully deficient and incomplete,' failing to provide necessary data on water resource impacts, climate change, and the full scope of associated infrastructure to allow for an informed decision.
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Document type: Statement
ENVIRONMENTAL IMPACT ASSESSMENT FOR THE PROPOSED METALLURGICAL CLUSTER OF THE MUSINA-MAKHADO SPECIAL ECONOMIC ZONE
The Centre for Environmental Rights (CER), representing Earthlife Africa, groundWork, and the Mining and Environmental Justice Community Network of South Africa (MEJCON-SA), submitted a formal objection to the Department of Economic Development Environment and Tourism in Limpopo regarding the Environmental Impact Assessment (EIA) for the Musina-Makhado Special Economic Zone (MMSEZ) metallurgical cluster. The CER argues that the Final Environmental Impact Report (FEIR) contains fatal flaws, including insufficient public participation and missing critical data on water and energy, and asserts that the application should have been refused by the regulatory deadline of 19 May 2021.
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Document type: Statement
OBJECTIONS TO THE 7 DECEMBER 2020 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT [REVISION 01] OF THE PROPOSED MUSINA-MAKHADO SPECIAL ECONOMIC ZONE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE
The Centre for Environmental Rights (CER), representing groundWork, Earthlife Africa, and the Mining and Environmental Justice Community Network of South Africa, submitted formal objections to the Revised Draft Environmental Impact Assessment (EIA) for the proposed Musina-Makhado Special Economic Zone (EMSEZ). The CER argues that the EIA is fatally flawed due to procedural unfairness, inadequate public participation, and significant gaps in specialist studies regarding climate change, water scarcity, air quality, and human health. The document asserts that the project's high negative environmental impacts likely outweigh its projected socio-economic benefits and that an environmental authorisation should be denied.
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Document type: Statement
ESKOM’S INTENDED APPLICATIONS FOR EXEMPTION FROM COMPLIANCE WITH THE MINIMUM EMISSION STANDARDS UNDER THE NATIONAL ENVIRONMENTAL MANAGEMENT: AIR QUALITY ACT 39 OF 2004
A statement from the Life After Coal campaign (LAC) to the South African Minister of Environment, Forestry and Fisheries, objecting to Eskom's attempts to seek exemptions from the Minimum Emission Standards (MES) under the National Environmental Management: Air Quality Act 39 of 2004.
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Document type: Statement
OBJECTIONS TO THE DRAFT ENVIRONMETAL IMPACT ASSESSMENT REPORT OF THE PROPOSED MUSINA-MAKHADO SPECIAL ECONOMIC ZONE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE
The Centre for Environmental Rights (CER), representing groundWork, Earthlife Africa (ELA), and MEJCON-SA, submitted formal objections on 22 October 2020 to the Draft Environmental Impact Assessment Report (DEIR) for the proposed Musina-Makhado Special Economic Zone (MMSEZ), also known as the Energy Metallurgical Special Economic Zone (EMSEZ). The CER argues that the project's negative environmental and social impacts far outweigh its potential benefits and that the environmental authorisation (EA) should be refused due to severe flaws in the assessment process, conflict of interest in the decision-making authority, and significant threats to climate, water, and health.
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Document type: Statement
OBJECTIONS TO ESKOM’S APPLICATIONS FOR ALTERNATIVE LIMITS TO THE MINIMUM EMISSION STANDARDS (MES) FOR THE MEDUPI AND MATIMBA POWER STATIONS
The Life After Coal campaign, comprising the Centre for Environmental Rights (CER), groundWork (gW), and Earthlife Africa (ELA), submitted formal objections on 28 August 2020 against Eskom's applications for alternative emission limits at the Medupi and Matimba power stations. The campaign argues that these requests are an unlawful attempt to circumvent South Africa's Minimum Emission Standards (MES) and violate constitutional rights to a healthy environment.
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Document type: Statement
WRITTEN OBJECTIONS TO ESKOM’S APPLICATION FOR A ONCE-OFF SUSPENSION OF COMPLIANCE WITH THE NEW PLANT MINIMUM EMISSION STANDARDS AND VARIATION REQUEST FOR THE GROOTVLEI POWER STATION
The Centre for Environmental Rights (CER), acting as part of the Life After Coal campaign and other environmental justice networks, submitted written objections on July 30, 2020, against Eskom's application for a once-off suspension of compliance with New Plant Minimum Emission Standards (MES) and a variation request for the Grootvlei Power Station. The CER argues that the application is procedurally invalid, lacks a detailed decommissioning schedule, and unlawfully seeks to extend polluting activities beyond the station's end-of-life, thereby violating constitutional rights to a healthy environment.
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Document type: Statement
OBJECTIONS TO GENERATION LICENCE APPLICATIONS FOR THABAMETSI AND KHANYISA IPP COAL-FIRED POWER STATIONS
The Centre for Environmental Rights (CER) wrote to the National Energy Regulator of South Africa (NERSA) on 17 February 2020, requesting updates on generation licence applications for the Thabametsi and Khanyisa coal-fired Independent Power Producer (IPP) power stations. The CER highlights significant delays since the March 2018 hearings and argues that the applications are now based on outdated information due to legal challenges, lapsed authorisations, and the withdrawal of bank financing.
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Document type: Statement
COMMENTS ON THE BACKGROUND INFORMATION DOCUMENT FOR ESKOM’S APPLICATION FOR ALTERNATIVE LIMITS TO THE MINIMUM EMISSION STANDARDS (MES) FOR THE MEDUPI AND MATIMBA POWER STATIONS
The Life After Coal campaign, comprising the Centre for Environmental Rights (CER), groundWork, and Earthlife Africa Johannesburg, submitted formal objections on 29 January 2020 to Eskom's applications for alternative emission limits at the Medupi and Matimba power stations. The campaign argues that the applications are procedurally and substantively unlawful, violate the South African Constitution and environmental laws, and rely on a flawed air quality modelling approach in a priority area already suffering from poor air quality.
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Document type: Statement
OBJECTIONS TO THE FINAL SCOPING ASSESSMENT REPORT OF THE PROPOSED MUSINA- MAKHADO SPECIAL ECONOMIC ZONE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE
The Centre for Environmental Rights (CER), representing groundWork and Earthlife Africa, submitted formal objections on November 1, 2019, to the Final Scoping Assessment Report (FSR) for the proposed Musina-Makhado Special Economic Zone (also known as the Energy Metallurgical Special Economic Zone or EMSEZ). The CER argues that the FSR is fatally flawed due to inadequate public participation, a failure to conduct a Strategic Environmental Assessment (SEA), and the appointment of an incorrect competent authority. The document details severe concerns regarding the project's impact on water scarcity, climate change, air quality, and biodiversity in the Limpopo Province.
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Document type: Statement
THE PROPOSED MUSINA-MAKHADO SPECIAL ECONOMIC ZONE INFRASTRUCTURE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE
The Centre for Environmental Rights (CER), representing groundWork and Earthlife Africa, submitted a formal statement to the Minister of Environment, Forestry and Fisheries opposing the proposed Musina-Makhado Special Economic Zone (SEZ), also known as the South African Energy and Metallurgical Special Economic Zone (EMSEZ). The CER argues that the project's environmental impact assessment (EIA) process is fatally flawed and that the project poses severe risks to water resources, air quality, and climate commitments.
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Document type: Statement
OBJECTIONS TO THE 22 MAY 2019 PROPOSED AMENDMENTS TO THE LIST OF ACTIVITIES AND ASSOCIATED MINIMUM EMISSION STANDARDS IDENTIFIED IN TERMS OF SECTION 21 OF THE NATIONAL ENVIRONMENTAL MANAGEMENT: AIR QUALITY ACT 39 OF 2004
The Centre for Environmental Rights (CER), representing the Life After Coal campaign and several environmental justice alliances, formally objects to a proposed amendment by the Department of Environment, Forestry and Fisheries to double the Sulphur Dioxide (SO2) Minimum Emission Standard (MES) for new plants in sub-category 1.1 from 500 mg/Nm3 to 1000 mg/Nm3. The CER argues that this weakening of standards is unlawful, violates the South African Constitution's right to a healthy environment, and would lead to significant premature deaths and exacerbated air pollution in priority areas.
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Document type: Statement