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REQUEST FOR URGENT WITHDRAWAL OF THE PROVISION IN THE LIST OF ACTIVITIES REGARDING THE WEAKENING OF THE SULPHUR DIOXIDE NEW PLANT MINIMUM EMISSION STANDARDS FOR EXISTING PLANTS
The Centre for Environmental Rights (CER), acting on behalf of several environmental campaigns and alliances, requested that the South African Department of Environmental Affairs urgently withdraw a provision in the amended List of Activities published on 31 October 2018. The CER argues that this provision improperly weakens the sulphur dioxide (SO2) minimum emission standards (MES) for existing solid-fuel combustion plants without public consultation.
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Document type: Statement
Integrated Resource Plan 2018 – groundWork comment
The commentary argues that the IRP 2018 is a form of 'climate denial' that lacks a meaningful carbon constraint and continues to prioritize coal and gas over cheaper, cleaner renewables. It highlights the severe health costs of air pollution from Eskom and criticizes the public consultation process as exclusionary. The authors advocate for a total phase-out of coal, the rejection of new extractive gas projects, and a transition to a socially owned renewable energy system that creates jobs and ensures energy justice for the poor.
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Document type: Statement
The Trump Administration Takes a Dangerous New Path in Proposing Changes to EPA’s Mercury and Air Toxics Rule
The Clean Air Task Force criticizes the Trump EPA's plan to revise the Mercury and Air Toxics Standards (MATS), asserting that the administration is intentionally ignoring the vast health benefits of the rule—such as 11,000 fewer premature deaths annually—to justify a rollback. The author contends that by limiting the benefit-cost analysis to mercury alone, the EPA is abandoning established regulatory principles to serve the interests of private coal company owners, despite the rule's high cost-effectiveness and the opposition of the utility industry that has already implemented the controls.
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Document type: Statement
Microsoft Word - Letter to TrudeauClimateHealth2018
Health professionals argue that the Trans Mountain pipeline expansion (TMX) poses significant risks to public health and the environment, claiming that the National Energy Board's review process was flawed and failed to account for climate-related health impacts and the toxicity of diluted bitumen.
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Document type: Statement
Michelin’s Greenwashing Must End. It’s Time for Sustainable Rubber Production.
Mighty Earth criticizes Michelin for failing to lead the tire industry in ending deforestation and land-grabbing caused by rubber harvesting in Southeast Asia and Africa, calling for the inclusion of civil society in the Global Platform for Sustainable Natural Rubber.
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Document type: Statement
Happy National Child Health Day?
The author criticizes the EPA for moving to undermine the Mercury and Air Toxics Standards (MATS), which reduce mercury and other air toxics from coal- and oil-fired power plants. The document highlights that MATS prevents 11,000 premature deaths and 130,000 asthma hospitalizations annually, noting that the EPA is using the benefits of MATS in its modeling to justify other rule rollbacks, such as the ACER rule, while simultaneously seeking to weaken MATS itself.
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Document type: Statement
EU Commission’s new illegal attempt to weaken the control of endocrine disruptors used in Pesticides – call for action
ClientEarth calls on EU Member States and the European Parliament to veto a European Commission proposal that seeks to change the conditions for using endocrine disruptors (EDCs) in pesticides. The document argues that the Commission is attempting to replace a ban based on 'negligible exposure' with one based on 'negligible risk', which ClientEarth claims is an illegal encroachment on the powers of the EU legislature and is not supported by new scientific evidence.
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Document type: Statement
Combatir el hambre y enfriar el clima con la Agroecología
The briefing contends that industrial agriculture drives climate change and food insecurity, and that 'climate-smart agriculture' serves as a corporate tool to maintain existing power structures. It proposes agroecology—combining traditional practices and ecological principles—as a superior alternative that increases climate resilience, reduces greenhouse gas emissions, and supports food sovereignty for small-scale producers.
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Document type: Briefing
CATF Statement on Final BLM Methane Waste Rule Final Rollback
The Clean Air Task Force (CATF) condemns the rollback of the BLM Methane Waste Rule, noting that the rule previously reduced annual methane emissions by 175,000-180,000 tons. CATF asserts that the rollback will cost taxpayers millions of dollars due to wasted natural gas and increased air pollution, while threatening the health of tens of thousands of people living near oil and gas wells on public lands.
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Document type: Statement
SUBMISSIONS ON THE BACKGROUND INFORMATION DOCUMENT (BID) FOR ESKOMassung FOR POSTPONEMENT OF THE MINIMUM EMISSION STANDARDS (MES) FOR 14 OF ITS COAL AND LIQUID FUEL-FIRED POWER STATIONS
The Life After Coal campaign, representing several environmental and community alliances, strongly objects to Eskom's request to postpone Minimum Emission Standards (MES) for 14 coal and liquid fuel-fired power stations. The submission argues that under the National Environmental Management: Air Quality Act (AQA) and the associated Framework, postponements are only permissible if ambient air quality standards in the area are in compliance, which is not the case for the Highveld Priority Area (HPA), Vaal Triangle Airshed Priority Area (VTAPA), and Waterberg-Bojanala Priority Area (WBPA). The document highlights severe health impacts, including thousands of premature deaths attributed to PM2.5 emissions, and criticizes Eskom's Background Information Document (BID) for being inaccurate and incomplete. The campaign demands the rejection of the applications, the cessation of 'rolling postponements', and a just transition toward renewable energy.
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Document type: Statement
Comments on the pollinator re-evaluation of imidacloprid
The document argues that the PMRA's proposed phase-out of imidacloprid is too slow and narrow in scope, failing to account for the risks to wild pollinators beyond honey bees and bumblebees. It criticizes the reliance on label statements for risk mitigation, citing inadequate enforcement capacity in Canada. The authors highlight risks from environmental contamination, such as residues in non-target wildflowers and dust from treated seeds, and argue that the economic value of neonicotinoid seed treatments is overrated. They recommend a full ban on all outdoor uses, aligned with European Union regulations, and a shift toward Integrated Pest Management (IPM).
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Document type: Statement
CATF Statement on Proposed Repeal of Clean Power Plan
The Clean Air Task Force opposes the EPA's proposed replacement of the Clean Power Plan, arguing it violates the Clean Air Act and would lead to approximately 1,000 avoidable deaths per year by extending the operation of old coal plants.
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Document type: Statement
Trump’s Power Plan Will Lead to More Emissions, Costs and Deaths
The World Resources Institute argues that the Trump administration's proposal to replace the Clean Power Plan will undermine U.S. climate strategy by providing loopholes for power plants, leading to higher greenhouse gas emissions and up to 1,400 premature deaths annually.
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Document type: Statement
THE DEVELOPMENT BANK OF SOUTHERN AFRICA’S ROLE IN FINANCING PROPOSED NEW COAL-FIRED POWER PLANTS
The CER argues that the DBSA's potential financing of the Thabametsi and Khanyisa coal-fired power plants contradicts its mandate for sustainable development and violates constitutional environmental rights. The CER highlights that these projects face significant legal challenges regarding licenses and would result in greenhouse gas emission intensities nearly 60% higher than Eskom's Medupi and Kusile plants. Furthermore, the CER cites evidence that South Africa has surplus base supply capacity and that these plants would increase costs by R19.68 billion compared to a least-cost energy system.
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Document type: Statement
GRIEVANCES ABOUT THE PARTICIPATION OF THE CENTRE FOR ENVIRONMENTAL RIGHTS
The Centre for Environmental Rights (CER) and a coalition of eight civil society organisations defend their legal opposition to a proposed coal mine by Atha-Africa Ventures (Pty) Ltd. CER argues that the mine would threaten a Strategic Water Source Area and a protected environment, while asserting that coal mining in Mpumalanga has historically failed to alleviate poverty or provide sustainable local employment. The document clarifies that CER does not represent local farmers or WWF-SA and disputes claims that its actions are 'anti-development', citing the constitutional right to a healthy environment.
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Document type: Statement
International Energy Charter Draft Model Investment Dispute Prevention and Management Protocol
The International Institute for Sustainable Development (IISD) critiques the International Energy Charter's draft Model Investment Dispute Prevention and Management Protocol, asserting that the instrument overreaches legally and could increase legal jeopardy for states in arbitration contexts. While supporting the development of internal state procedures for dispute management, IISD argues these should be based on guidance and good practice rather than a rigid legal instrument.
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Document type: Policy brief
RESPONSE TO LETTER OF 16 JULY 2018 AND INPUT REGARDING THE JUST ENERGY TRANSITION TO A LOW-CARBON FUTURE FOR THE PEOPLE OF SOUTH AFRICA
The Life After Coal Campaign (LAC) argues that new coal-fired power plants in South Africa are irrational, costly, and contrary to international climate obligations. The campaign highlights the severe water externalities of coal, the health risks associated with the proposed Khanyisa power station, and the financial risks of stranded assets as global investment shifts away from thermal coal. LAC advocates for a just transition that prioritizes renewable energy, protects workers' livelihoods, and ensures Eskom's active role in a sustainable energy system.
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Document type: Statement
COAL BASELOAD INDEPENDENT POWER PRODUCERS – STATUS OF THE POWER PURCHASE AGREEMENTS
The Centre for Environmental Rights (CER), on behalf of the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, has written to Eskom to challenge the procurement of two coal-fired independent power producers (IPPs): Thabametsi and Khanyisa. The CER argues that these projects are not 'value for money' as they would increase system costs by 19.6 billion Rand, raise greenhouse gas emissions, and risk becoming stranded assets. The letter highlights that the projects lack necessary licenses and are subject to pending High Court reviews. It requests detailed information on the status of the PPAs, the 'value for money' assessment, and compliance with the Public Finance Management Act (PFMA) and New Generation Regulations.
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Document type: Statement
Earthjustice Statement on Anti-Environment Interior Appropriations Bill
Earthjustice opposes the House's Interior and Environment Appropriations bill, citing over $100 million in cuts to the EPA and Department of the Interior, as well as provisions that fast-track coastal drilling and threaten the Arctic National Wildlife Refuge.
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Document type: Statement
EPA Report on Biofuels Environmental Impacts Misses the Fore
The Environmental and Energy Study Institute criticizes a June 30, 2018, EPA report for omitting a comparative analysis between biofuels and petroleum. The statement asserts that biofuels generally offer better environmental and health outcomes than fossil fuels and highlights the role of cellulosic fuels in reducing methane emissions and waste. It further argues that biofuels are essential for meeting Paris Climate Accord goals, particularly in hard-to-electrify sectors like aviation and shipping.
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Document type: Statement