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This document consists of a formal submission by the Centre for Environmental Rights (CER) and an accompanying independent peer review by Carin Bosman Sustainable Solutions (CBSS). It critiques the Integrated Water Use Licence Application (IWULA) Report prepared by Jones and Wagner for KiPower's proposed 600 MW coal-fired power station in Mpumalanga, South Africa. The CER and CBSS conclude that the IWULA is 'Inadequate' due to significant procedural and substantive failures, including the absence of a practical Integrated Water and Waste Management Plan (IWWMP) Action Plan and a failure to adequately assess impacts on groundwater and other water users.

The Centre for Environmental Rights (CER), representing several community and environmental groups, submitted a formal reply on 24 March 2014 challenging Eskom's applications for postponement from the Minimum Emission Standards (MES). The CER disputes Eskom's claims that its power stations have a marginal impact on air quality and health, arguing that Eskom's Atmospheric Impact Reports (AIRs) are anecdotal, use insufficient modeling domains, and fail to quantify the health risks associated with secondary PM2.5 formation and mercury emissions.

The Centre for Environmental Rights (CER), acting for several environmental justice organisations, submitted comments on the Department of Environmental Affairs' (DEA) Draft Air Quality Offset Policy. The CER and its clients oppose the use of offsets in principle, arguing they serve as a "cheap option to avoid compliance" with emission standards and could undermine the constitutional right to a healthy environment. The submission highlights significant gaps in the draft policy, including a lack of clear criteria for determining offsets, poor institutional capacity for monitoring and enforcement, and failure to address equity and distributional effects.

The Centre for Environmental Rights (CER), representing several environmental justice organisations, submitted comments on 21 February 2014 regarding the Draft National Atmospheric Emissions Inventory System (NAEIS) Reporting Regulations. The submission primarily argues that the draft regulations fail to ensure adequate public access to atmospheric emission data and provides recommendations to align the regulations with constitutional rights to information and a healthy environment.

The Centre for Environmental Rights (CER) argues that Eskom's requests to postpone compliance with the National Environmental Management: Air Quality Act (AQA) should be denied due to flawed atmospheric modelling, exaggerated compliance costs, and significant risks to human health. The CER contends that Eskom fails to meet the legal requirements for postponement, particularly regarding the impact on declared Priority Areas. Furthermore, the document critiques Eskom's proposal for emission offsets as lacking a legal basis and sufficient data, while highlighting that granting these postponements would lead to substantial increases in SO2, NOx, and PM10 emissions through 2020.

A joint submission by environmental organisations to the South African Portfolio Committee on Mineral Resources regarding the MPRDA Amendment Bill. The authors support the principle that mining right holders remain responsible for environmental liabilities regardless of a closure certificate but strongly oppose a proposed 20-year limit on the Minister's ability to retain financial provisions for latent impacts, arguing that such a period is arbitrary and often insufficient to cover long-term issues like acid mine drainage.

The document argues that Eskom's applications for emission standard postponements and exemptions are legally invalid because ambient air quality standards (AAQS) are already exceeded in the affected priority areas. It highlights significant health risks, particularly from SO2 and mercury, and criticizes Eskom for failing to consider feasible alternatives such as renewable energy or decommissioning worst-performing plants. The submission also references a World Bank Inspection Panel report on the Medupi Power Plant, which found inadequate consideration of environmental principles, water scarcity risks, and cumulative health impacts.

The Center for International Environmental Law (CIEL) submits that stringent chemical regulations incentivize the development of safer alternatives, citing patent spikes for phthalate-alternatives as evidence. It criticizes TSCA Section 5 for allowing 'regrettable substitution' due to insufficient safety data and TSCA Section 14 for the abuse of confidential business information (CBI) privileges. CIEL recommends shifting the burden of proof for safety to manufacturers, increasing information transparency, and phasing out endocrine disrupting chemicals.

The Centre for Environmental Rights (CER), representing groundWork, the South Durban Community Environmental Alliance (SDCEA), and the Vaal Environmental Justice Alliance (VEJA), submitted comments on 16 April 2013 regarding the draft 2012 National Framework for Air Quality Management in South Africa. The CER argues that the Department of Environmental Affairs (DEA) failed to follow prescribed review processes, ignored legislative obligations from the 2007 Framework, and provided insufficient support to municipalities for air quality management.

The Centre for Environmental Rights (CER), acting for groundWork and the Vaal Environmental Justice Alliance (VEJA), submitted a statement to the Department of Environmental Affairs on 31 January 2012. The document objects to proposed amendments to the National Environmental Management: Air Quality Act, 2004’s list of activities resulting in atmospheric emissions, arguing that the changes generally relax emission limits, extend compliance time-frames, and were developed through a non-transparent process that favored industry representatives over affected communities.

The Centre for Environmental Rights (CER) argues that the South African Weather Service Amendment Bill, 2011, introduces problematic penalties for issuing air pollution-related warnings without permission. CER contends this could criminalise independent air quality monitoring and contradict existing protections in the National Environmental Management Act (NEMA). They propose removing the 'air pollution-related warning' offence and explicitly aligning the Weather Service's objectives with the Constitution and NEMA.

The Centre for Environmental Rights (CER) provides detailed legal and technical submissions on the draft Air Quality Management By-law for the Ngkawi District Municipality (NDM). The CER recommends aligning the by-laws with national legislation, such as the National Environmental Management: Air Quality Act (AQA) and the National Environmental Management Act (NEMA), and suggests stricter local emission and dust standards to protect human health, particularly given the area's location within a High Priority Area (HPA).

This document is a replying submission by Atha-Africa Ventures (Pty) Ltd to the Director-General of the Department of Mineral Resources. It responds to an administrative appeal lodged by a coalition of environmental organisations against the approval of the Environmental Management Programme (EMP) for the Yzermyn Underground Coal Mine Project.

The Legal Resources Centre (LRC) submitted a statement to the Portfolio Committee on Water and Environmental Affairs on 7-8 May 2013, opposing proposed amendments to the Section 21 listed activities of the Air Quality Act (Act 39 of 2004). The LRC argues that the 2012 amendment process lacked administrative fairness and transparency compared to the 2009 process, resulting in reduced standards for major polluters and extended compliance timeframes.

This responding statement, submitted by groundWork to the Department of Forestry, Fisheries and the Environment (DFFE), argues for the dismissal of Karpowership SA (PTY) Ltd’s appeal against the refusal of an Environmental Authorisation (EA) for a gas-to-power project in Richards Bay. groundWork contends that the project is neither necessary nor desirable, citing significant environmental risks, inadequate public participation, and the existence of more cost-effective, renewable energy alternatives.

The Centre for Environmental Rights (CER) and the Legal Resources Centre (LRC) provided joint submissions on 18 July 2012 regarding the National Environmental Management Laws Amendment Bill, 2012. The document offers a detailed critique of proposed amendments to the National Environmental Management Act (NEMA), the Biodiversity Act, and the Air Quality Act, focusing on environmental governance, criminal liability, and the rights of traditional communities.

This document consists of a practice note and legal submissions filed by the National Minister of Water and Environmental Affairs to the Constitutional Court of South Africa. The submissions argue that holders of mining rights or permits granted under the Mineral and Petroleum Resources Development Act (MPRDA) are not exempt from obtaining separate environmental authorisations under the National Environmental Management Act (NEMA) for listed activities.

This document is a replying submission by Atha-Africa, submitted on 12 April 2019, responding to an administrative appeal against the approval of the Environmental Management Programme (EMP) for the Yzermyn Project. The submission disputes the findings of a September 2013 NSS Report and a subsequent 'Brownlie Review,' arguing that updated specialist studies by Delta-H and Scientific Aquatic Services demonstrate that the project's environmental impacts—specifically regarding wetlands, groundwater, and biodiversity—are localized and can be effectively mitigated.

This document consists of the final submissions made by the International Institute for Sustainable Development (IISD) on October 16, 2000, to an arbitral tribunal. The IISD is petitioning for amicus curiae status in the Chapter 11 NAFTA arbitration between Methanex Corporation and the United States of America, arguing that the case involves significant public interest and environmental issues that warrant independent legal perspectives.

Natural Justice challenges the Basic Assessment Reports (BARs) for four prospecting projects in South Africa's West Coast region, citing 'fatal flaws' in biodiversity and water supply assessments. The organization argues that the reports ignore climate change commitments, fail to meaningfully consult vulnerable groups like the Guriqua communities, and overlook the potential destruction of sacred cultural sites and the impact on the region's primary agricultural and fishing sectors.