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Further comment on draft South African Renewable Energy Masterplan (July 2023): Gender equality, gender justice and women’s participation
The Centre for Environmental Rights, on behalf of the Life after Coal Campaign, submitted further comments on the draft South African Renewable Energy Masterplan (SAREM) in August 2023. The submission argues that gender equality and justice must be a deliberate, central outcome of the energy transition rather than an afterthought, as systemic patriarchy and existing discrimination currently limit women's participation in the renewable energy sector.
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Document type: Statement
LIFE AFTER COAL COMMENTS ON DRAFT 8TH NATIONAL GREENHOUSE GAS INVENTORY REPORT
The Centre for Environmental Rights, representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted comments on the Draft 8th National Greenhouse Gas Inventory Report (NGHGIR) on 31 August 2022. The submission argues that the draft significantly undercounts methane emissions due to the omission of fugitive emissions from the oil and gas industry, pipeline transport, and abandoned mines, and criticizes the use of outdated global warming potential (GWP) metrics and low emission factors for coal mining.
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Document type: Statement
LIFE AFTER COAL CAMPAIGN COMMENTS ON THE DRAFT REGULATIONS AMENDING THE ELECTRICITY REGULATIONS ON NEW GENERATION CAPACITY, 2011
The Centre for Environmental Rights (CER), on behalf of the Life After Coal Campaign, submitted comments on the Draft Regulations Amending the Electricity Regulations on New Generation Capacity, 2011. The CER argues that the Draft Regulations are redundant and legally inconsistent because the Electricity Regulation Act (ERA) does not require prior Ministerial approval for municipalities to establish their own electricity capacity. The submission emphasizes the urgent need for a transition to clean energy to mitigate severe health, environmental, and climate harms caused by South Africa's coal-dependent power sector.
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Document type: Statement
COMMENTS ON CONSULTATION PAPER 1: CONCURRENCE WITH THE MINISTERIAL DETERMINATION ON THE PROCUREMENT OF NEW GENERATION CAPACITY FROM A RANGE OF ENERGY TECHNOLOGIES 2020
The Centre for Environmental Rights (CER), writing on behalf of the Life After Coal Campaign, submitted comments to the National Energy Regulator of South Africa (NERSA) regarding a draft ministerial determination to procure 2,000 MW of new generation capacity. The CER argues that this procurement must prioritize clean, affordable, and renewable energy sources over fossil fuels to align with constitutional obligations and public interest, while criticizing the lack of transparency regarding Request for Information (RFI) responses and the inadequacy of the public consultation process.
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Document type: Statement
Comments on the Canada Gazette Part I, Vol. 152, No. 7 — February 17, 2018, Regulations Amending the Reduction of Carbon Dioxide Emissions from Coal-fired Generation of Electricity Regulations
A submission by the Canadian Association of Physicians for the Environment (CAPE) and several other health organizations supporting the phase-out of coal-fired electricity generation in Canada by 2030. The document argues that coal plants are major sources of greenhouse gases and toxic pollutants, such as mercury and criteria air contaminants, which cause significant respiratory and cardiovascular diseases and developmental issues in children.
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Document type: Statement
Regulations Limiting Carbon Dioxide Emissions from Natural Gas-fired Generation of Electricity
A submission by the Canadian Association of Physicians for the Environment (CAPE) and several health-focused organizations providing comments on the proposed Regulations Limiting Carbon Dioxide Emissions from Natural Gas-fired Generation of Electricity. While supporting the phase-out of coal by 2030, the coalition warns that relying on inefficient natural gas technologies could undermine health and climate benefits due to upstream methane emissions and the release of nitrogen oxides (NOx).
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Document type: Statement
ADDITIONAL WRITTEN COMMENTS ON THE INTEGRATED RESOURCE PLAN (IRP) UPDATE: ASSUMPTIONS, BASE CASE RESULTS AND OBSERVATIONS, REVISION 1 AND ON THE DRAFT INTEGRATED ENERGY PLAN (IEP)
The Centre for Environmental Rights (CER), representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted additional comments to the South African Department of Energy regarding the Integrated Resource Plan (IRP) and Integrated Energy Plan (IEP). The CER argues that these plans must incorporate missing cost calculations for coal and nuclear energy, as well as findings from recent studies suggesting that accelerating the decommissioning of coal plants and cancelling new coal and nuclear capacity is the most cost-effective path for Eskom and the national grid.
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Document type: Statement
Health Collaborative Comments on the Notice of Intent to develop Greenhouse Gas regulations for Electricity Generation in Canada
A submission from a collaborative of eight health organizations to Environment and Climate Change Canada advocating for an accelerated phase-out of coal-fired power plants to maximize public health and climate benefits.
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Document type: Statement
COMMENTS BY THE CENTRE FOR ENVIRONMENTAL RIGHTS ON THE PROPOSED AMENDMENTS TO THE FINANCIAL PROVISIONING REGULATIONS, 2015
The Centre for Environmental Rights (CER) submitted comments to the Department of Environmental Affairs on October 7, 2016, regarding proposed amendments to the Financial Provisioning Regulations, 2015. The CER argues that several proposed deletions of appendices and clauses would create legal uncertainty, reduce transparency, and weaken the state's ability to ensure that mining rehabilitation funds are available and used correctly.
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Document type: Statement
Comments on the Draft Declaration of Greenhouse Gases as Priority Pollutants & the National Pollution Prevention Plans Regulations
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.
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Document type: Statement
CER COMMENTS ON THE UPDATED MULTI-STAKEHOLDER REFERENCE GROUP TERMS OF REFERENCE FOR THE IMPLEMENTATION OF THE HIGHVELD PRIORITY AREA AIR QUALITY MANAGEMENT PLAN
The Centre for Environmental Rights (CER), acting on behalf of several community and environmental organisations, submitted comments on 11 December 2015 regarding the updated Terms of Reference (ToR) for the implementation of the Highveld Priority Area (HPA) Air Quality Management Plan (AQMP). The CER argues that the ToR must be expanded to ensure broader government participation, mandatory attendance from industry and municipal leaders, and improved transparency and accessibility of air quality data and meeting documentation.
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Document type: Statement
Additional comments to the declaration of greenhouse gases as priority pollutants
The Centre for Environmental Rights submitted additional comments to the Department of Environmental Affairs regarding the declaration of greenhouse gases as priority pollutants, specifically requesting clearer distinctions in the classification of land use and land use change.
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Document type: Statement
Comments regarding the declaration of greenhouse gases as priority air pollutants
The Centre for Environmental Rights, representing several environmental justice organisations and community groups, submitted comments to the Department of Environmental Affairs regarding the declaration of greenhouse gases (GHGs) as priority air pollutants. The submission specifically argues that natural ecosystems should be excluded from the requirement to submit pollution prevention plans.
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Document type: Statement
Comments on the Draft National Atmospheric Emissions Inventory System (NAEIS) Reporting Regulations
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.
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Document type: Statement
Comments on the Renewable Fuel Standard Assessment White Paper: Agricultural Sector Impacts
The Environmental and Energy Study Institute (EESI) submitted comments to the U.S. House of Representatives advocating for the maintenance of the Renewable Fuel Standard (RFS) as written. EESI argues that the RFS is critical for reducing petroleum dependence, improving urban air quality by reducing aromatic air toxics, and fostering rural economic development. The document contends that factors other than the RFS—such as extreme weather, global meat demand, and commodity speculation—are the primary drivers of corn and soybean price volatility.
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Document type: Statement
SUBMISSIONS ON THE DRAFT NATIONAL DUST CONTROL REGULATIONS PUBLISHED IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT: AIR QUALITY ACT, 2004 (AQA)
The Centre for Environmental Rights, acting on behalf of groundWork, the South Durban Community Environmental Alliance (SDCEA), and the Vaal Environmental Justice Alliance (VEJA), submitted comments on 5 February 2013 regarding the draft National Dust Control Regulations published on 7 December 2012 under the National Environmental Management: Air Quality Act, 2004 (AQA). The submission argues for stronger protections for vulnerable populations, more rigorous monitoring standards, and the inclusion of government entities in enforcement.
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Document type: Statement
Comment on The American Physical Society Hydrogen Report
Amory B. Lovins of the Rocky Mountain Institute (RMI) critiques the March 2004 American Physical Society (APS) report "The Hydrogen Initiative," arguing that it reaches erroneous conclusions regarding hydrogen economics and storage due to outdated assumptions and methodological flaws.
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Document type: Statement
Comments on FERC's "Mega-NOPR"
RMI provides comments to the Federal Energy Regulatory Commission (FERC) regarding its March 1995 Notice of Proposed Rulemaking (NOPR) on open-access transmission. The document argues for symmetrical economic rewards for demand-side resources and warns that rapid technological advances in distributed generation could render central thermal power plants and the traditional utility model obsolete.
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Document type: Statement
2014-05-30-fa33-sapia-letter-to-dea-28-08-2009-163f0dfb691f3316.pdf
A letter from the South African Petroleum Industry Association (SAPIA) to the Director-General of Environmental Affairs dated 28 August 2009, providing comments and proposed amendments to the Listed Activities and Minimum Emission Standards published in Government Notice No. 32434 of 24 July 2009.
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Document type: Statement
2014-05-30-fa34-rmef-comments-21-8-2009-be1aea94c7e212b4.pdf
The Refinery Managers’ Environmental Forum (RMEF) submitted comments on August 21, 2009, regarding proposed regulations under the National Environmental Management: Air Quality Act (NEMAQA) in South Africa. The RMEF argues that the proposed minimum emission standards are technically and economically unachievable for existing refineries, particularly the requirement for existing plants to meet new plant standards within eight years. They advocate for a 'bubble approach' to measure total site impact rather than point-source monitoring and request specific adjustments to particulate matter (PM) and volatile organic compound (VOC) limits to align with Best Available Techniques (BAT) and economic viability.
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Document type: Statement