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2014-05-30-fa56-notice-964-submission-by-natref-12-2012-d6e2e025dcf9eaaf.pdf
This document is a December 2012 submission by Natref to the Department of Environmental Affairs (DEA) regarding the draft Notice of Minimum Emission Standards (MES) under the National Environmental Management: Air Quality Act, 2004. Natref, South Africa's only inland oil refinery, argues that the proposed point-source emission limits for sulphur dioxide (SO2), particulate matter (PM), and nitrogen oxides (NOx) are technically and economically unfeasible due to its unique inland location, fuel oil requirements, and space constraints. The company advocates for a "bubble" approach to emissions management and requests differentiated limits based on fuel type to maintain business sustainability and ensure the success of the Clean Fuels II project.
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Document type: Statement
2014-05-30-fa57-email-from-sasol-to-dea-20-11-2013-2db5966aa2d5547e.pdf
This document is a submission from Sasol to the South African Department of Environmental Affairs (DEA) detailing the company's objections to the requirement that existing industrial plants meet 'new plant standards' for emissions by April 1, 2020. Sasol argues that retrofitting old facilities is often technically impossible due to space and configuration constraints, economically unviable, and potentially counterproductive to other environmental goals, such as carbon footprint reduction and water conservation.
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Document type: Report
2014-05-30-fa58-sapia-submission-23-12-2012-9221836ad499994f.pdf
The South African Petroleum Industry Association (SAPIA) submitted a set of comments and proposals to the Department of Environmental Affairs (DEA) on December 23, 2012, regarding the regulation of atmospheric emissions. The submission focuses on refining definitions, reporting requirements, compliance timeframes, and specific emission standards for combustion installations and petroleum product storage.
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Document type: Statement
annexure-a_gem08_l186_eskom_sumbission_emission_standards_nov08-1-442e7dd7bc5dd02e.pdf
A submission from Eskom to the South African government regarding proposed minimum emission standards for combustion installations, arguing for practical limits based on technological, resource, and cost constraints.
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Document type: Statement
annexure-g_submission-to-the-parliament-portfolio-committee-on-water-and-dea-april-2013-1-200121e7f260bef7.pdf
In a submission to the Parliament Portfolio Committee on Water and Environmental Affairs dated 12 April 2013, Eskom expresses concerns that full compliance with the Minimum Emission Standards (MES) for Listed Activities under the National Environmental Management: Air Quality Act, 2004, would threaten energy security and increase electricity tariffs. While supporting the act in general, Eskom argues that the standards ignore local scientific evidence and resource constraints, specifically regarding water availability and capital costs.
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Document type: Statement
cover-letter-cer-submissions-on-ndm-aqmp-by-law-_27-5-15-f703c28e373a7d09.pdf
A cover letter from the Centre for Environmental Rights (CER) submitting formal comments on the draft Air Quality Management Plan (AQMP) and Air Quality Management By-law for the Nkangala District Municipality on behalf of the Highveld Environmental Justice Network, groundWork, and Earthlife Africa, Johannesburg.
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Document type: Statement
fa35-submission-busa-dated-august-2009-8710f9ea67f6044a.pdf
Business Unity South Africa (BUSA) submitted a statement in August 2009 expressing concerns over proposed minimum emission limits. BUSA argues that the standards are unjustifiably stringent, deviate from previous industry discussions during the SABS process, and fail to account for the operational realities of upset conditions, potentially harming the competitiveness of South African manufacturing and exports.
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Document type: Statement
Comments About the Bill
Ember provides a submission on the Climate Change Bill 2022 and the Climate Change (Consequential Amendments) Bill 2022, arguing that Australia's emissions targets are implausible without aggressive action on coal mine methane (CMM). The document highlights that CMM dominates Australia's energy sector methane emissions and suggests that official figures may be significantly underestimated.
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Document type: Statement