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The Centre for Environmental Rights (CER), representing several environmental justice organisations, submitted provisional comments on June 29, 2018, regarding the Department of Environmental Affairs' (DEA) proposed amendments to the 2012 National Framework for Air Quality Management in South Africa. The CER argues that the public consultation process was inadequate and that the draft Framework fails to address systemic failures in air quality monitoring, enforcement, and the achievement of previous targets.

The Centre for Environmental Rights, representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted representations on June 25, 2018, regarding proposed amendments to the List of Activities resulting in atmospheric emissions. While supporting the elimination of 'rolling postponements' for minimum emission standards (MES), the submission argues for stricter requirements for once-off suspensions, greater transparency in application documents, and a more robust public participation process.

The Centre for Environmental Rights (CER), representing various community-based and non-governmental organisations, submits that the 2018 Draft Amendments to the National Dust Control Regulations fail to address critical weaknesses in dust emission management and monitoring in South Africa. The CER argues that the reliance on the ASTM D1739 test method is inappropriate as it masks short-term high-emission events and does not protect human health. They advocate for the inclusion of 'best practicable environmental measures' (BPEM), mandatory PM10 monitoring, and specific geochemical and radionuclide analysis for dust from tailings storage facilities. The submission also emphasizes the need for stronger local government enforcement, particularly in priority areas like the Highveld, and calls for the regulations to take effect immediately rather than on 1 November 2019.

The Centre for Environmental Rights (CER) submitted comments to the South African Department of Environmental Affairs (DEA) on the post-2020 mitigation system. The CER advocates for the use of the 'low peak plateau decline (PPD) trajectory' for mitigation ambition and strongly opposes the use of 'grandfathering' (historical emissions) to set carbon budgets, as it rewards polluters. The document emphasizes the necessity of public access to facility-level greenhouse gas (GHG) emission data, citing precedents in the EU, USA, and Australia, and objects to the DEA's use of Non-Disclosure Agreements to keep such data confidential. Regarding the carbon tax, the CER argues it should remain a distinct instrument from carbon budgets and should apply to all emissions rather than only those exceeding budgets. Additionally, the CER highlights an Energy Research Centre (ERC) report finding that proposed coal-fired power stations (Thabametsi and Khanyisa) are not least-cost, are unnecessary for demand, and would increase GHG emissions by 205.7Mt CO2eq over 30 years.

The Centre for Environmental Rights, on behalf of the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, urges the Portfolio Committee on Energy to compel the Department of Energy to release key technical data and conduct fair public consultations before finalising the IRP Update and IEP. The submission highlights the Department's failure to respond to PAIA requests for modelling assumptions and tariff implications. It further argues that the current planning ignores the health and water costs of coal, the emissions of nitrous oxide from CFB technology, and the financial viability of new coal and nuclear plants. Citing studies by Meridian Economics and the Frankfurt Institute, the document asserts that accelerating the decommissioning of older coal stations and prioritising wind and solar PV is the most cost-effective path for South Africa's energy future.

The Centre for Environmental Rights (CER) criticises the draft 2017 National Framework for Air Quality Management for failing to review progress against previous targets and for inadequate public participation. The submissions highlight persistent non-compliance with national ambient air quality standards in priority areas, severe delays in the implementation of the South African Air Quality Information System (SAAQIS), and deficiencies in greenhouse gas reporting. CER demands more transparent, facility-level GHG reporting, stricter air quality standards aligned with WHO guidelines, and the urgent appointment of air quality officers and inspectors to ensure enforcement of the Air Quality Act.

This document contains the legal and technical submissions made by a coalition of eight appellants (including Earthlife Africa Johannesburg and BirdLife South Africa) on August 14, 2017, appealing an environmental authorisation (EA) granted to Atha-Africa Ventures (Pty) Ltd for the Yzermyn underground coal mine in Mpumalanga, South Africa.

This document is a cover letter from the Centre for Environmental Rights (CER) to the South African Minister of Environmental Affairs, submitting further arguments on behalf of groundWork to appeal the environmental authorisation for the ACWA Power Khanyisa Thermal Power Station.

The Centre for Environmental Rights (CER) submits that the Mineral and Petroleum Resources Development Amendment Bill [B 15D-2013] is vulnerable to constitutional challenge due to procedural irregularities in Parliament. The CER argues that the Bill dilutes the rights of women and communities to benefit from mineral resources and fails to align environmental management of mines with the higher standards of the National Environmental Management Act (NEMA). Specifically, the CER opposes the 'deeming' of old-order environmental management programmes as NEMA authorisations, which it claims exonerates companies operating illegally. The submission also calls for the Department of Mineral Resources to be stripped of environmental regulation duties, citing a lack of capacity and an inherent conflict of interest between promoting mining and protecting the environment.

The Centre for Environmental Rights, acting for Earthlife Africa Johannesburg, submitted comments on the draft Climate Change Impact Assessment (CCIA) and Palaeontological Impact Assessment (PIA) for the proposed Thabametsi coal-fired power station. The submission argues that the draft CCIA significantly underestimates greenhouse gas emissions, ignores the social cost of carbon, and fails to adequately address severe water scarcity risks in the Lephalale area. The authors contend that the project is not in the national interest due to existing excess energy capacity and that the most appropriate recommendation is a 'no go option' to avoid irreversible environmental and social harm.

The Centre for Environmental Rights (CER), acting for Earthlife Africa Johannesburg, submitted comments to the Department of Environmental Affairs (DEA) regarding the Final Scope of Work Report (FSR) for the Thabametsi coal-fired power station. The CER argues that the FSR is inadequate, particularly concerning the Climate Change Impact Assessment (CCIA), and requests that the DEA either reject the report or require significant amendments to align it with the South African Constitution and the National Environmental Management Act (NEMA).

The Centre for Environmental Rights (CER), representing several environmental justice organisations, submitted comments on the 2016 Draft Strategy to Address Air Pollution in Dense Low Income Settlements. While welcoming the document, the CER argues that it lacks measurable plans, adequate baseline data, and a strategy for community consultation to effectively address the health impacts of domestic fuel burning in South Africa.

The document argues that poor environmental governance by the Department of Mineral Resources (DMR) and the Department of Water and Sanitation (DWS) leads to systemic violations of environmental rights in South Africa's mining sector. It highlights severe impacts on water resources, including acid mine drainage and the depletion of aquifers, and notes the destruction of strategic water source areas (SWSAs). The CER identifies critical failures in the Environmental Impact Assessment (EIA) process, citing insufficient timeframes for public participation and a lack of independence among practitioners. It recommends transferring environmental regulation of mines from the DMR to environmental authorities, implementing free prior and informed consent (FPIC) for communities, and establishing 'no-go' areas for mining in ecologically sensitive zones.

The Centre for Environmental Rights, acting for Earthlife Africa Johannesburg, submitted comments on the Background Information Document (BID) for the proposed Mokolo Crocodile (West) Water Augmentation Project Phase 2 (MCWAP-2). The submission expresses significant reservations regarding the project's sustainability and feasibility, citing climate change and water scarcity, and requests further clarity on the environmental impact assessment (EIA) process and public consultation.

The Centre for Environmental Rights (CER), on behalf of Earthlife Africa Johannesburg, provides recommendations to improve the scope of the Climate Change Impact Assessment (CCIA) and Palaeontological Impact Assessment Report (PIAR) for the proposed 1200MW Thabametsi coal-fired power station near Lephalale, Limpopo. The CER argues that the current scoping report is too narrow and fails to align with international best practices or South Africa's climate commitments under the Paris Agreement and its Intended Nationally Determined Contribution (INDC).

The Centre for Environmental Rights (CER), representing several environmental justice organisations, submitted comments on 8 February 2016 regarding the Draft Declaration of Greenhouse Gases as Priority Pollutants and the Draft National Pollution Prevention Plans (PPP) Regulations. The submission argues for greater alignment between these regulations and South Africa's international commitments under the Paris Agreement and its Intended Nationally Determined Contribution (INDC), while advocating for increased transparency, public access to data, and more rigorous monitoring and verification of greenhouse gas (GHG) emissions.

The Centre for Environmental Rights (CER), representing groundwork (gW), Earthlife Africa, Johannesburg (ELA), and the South Durban Community Environmental Alliance (SDCEA), submitted formal comments on the draft National Greenhouse Gas (GHG) Emission Reporting Regulations published on 5 June 2015. The CER argues that the draft regulations are insufficient to meet South Africa's international obligations under the UNFCCC and the Kyoto Protocol, citing a lack of detailed facility-level reporting, a failure to identify 'key categories' of emission sources as per IPCC Guidelines, and inadequate provisions for public disclosure of emission data.

The Centre for Environmental Rights (CER), representing several environmental justice alliances, submitted a formal objection to the Department of Environmental Affairs' draft Air Quality Offsets Guideline (January 2015). The CER argues that the proposed offsets are actually forms of compensation that lack a legislative framework and could be used by polluters to avoid legal compliance with emission standards.

The Centre for Environmental Rights (CER) provides detailed legal submissions on a draft Air Quality Management By-law, advocating for stronger public participation, mandatory rather than discretionary emission standards, and the removal of 'rectification' provisions for unlawful activities.

The Centre for Environmental Rights (CER) submitted a statement to the Department of Environmental Affairs (DEA) opposing Eskom's applications to postpone compliance with Minimum Emission Standards (MES). The CER argues that Eskom failed to provide required health impact assessments and future compliance plans, while monitoring data indicates that Eskom's emissions cause frequent, year-round exceedances of air quality guidelines, contributing to significant regional health risks.