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The Civil Society FfD Mechanism argues that the EU is negotiating in bad faith by attempting to undermine a February 2024 agreement on a UN Framework Convention on International Tax Cooperation (Para 27). The group also calls for the retention of Para 66 and Para 73, asserting that unilateral trade measures justified as climate actions create unbalanced barriers for Global South exports and hinder the transition to greener pathways. Finally, the statement demands full transparency for the FfD4 preparatory process, including live streaming and simultaneous sharing of texts with civil society, criticizing co-facilitators Spain and South Africa for failing to uphold these modalities.

The report by Climate Action Against Disinformation (CAAD) analyzes ten 'misleading claims' used by fossil fuel interests to delay the energy transition. It argues that fossil fuels are the primary driver of climate change, with 36.6 billion tonnes of the 40.5 billion global CO2 emissions in 2022 originating from their use. The document debunks claims that emissions—rather than fossil fuels themselves—are the problem, and challenges the industry's focus on Scope 1 and 2 emissions, noting that Scope 3 emissions account for 80-95% of total carbon emissions for oil and gas companies. It further critiques technological 'solutions' like Carbon Capture and Storage (CCS), Direct Air Capture (DAC), e-fuels, and 'blue' hydrogen, characterizing them as expensive, inefficient, or unproven at the scale required to limit warming to 1.5C. Finally, it argues that fossil fuel reliance hinders economic growth in Africa and Asia and exacerbates the global cost-of-living crisis.

The document highlights the severe health and environmental risks associated with the 300 square kilometers of tailings ponds in northern Alberta, noting unusually high cancer rates in Fort Chipewyan and the presence of toxic chemicals like arsenic and benzene. It criticizes the industry for underestimating air pollution and failing to report spills, while calling for an Indigenous-led health study and a moratorium on tailings pond growth.

The document contends that the EPA lacks the legal authority under sections 111 and 112 of the Clean Air Act to implement nationwide emission trading for hazardous air pollutants. It argues that these sections mandate uniform, source-specific performance standards rather than a tradeable allowance system. The author further claims that the EPA's approach is arbitrary and capricious because it fails to adequately address the risk of localized mercury 'hotspots' and includes flawed program elements, such as a 'safety valve' provision and exemptions for small emitters, which could delay the installation of pollution controls and maintain high emission levels.

The Clean Air Task Force (CATF) asserts that the EPA's proposed MACT regulations for utility units lack rigorous economic analysis and fail to protect children from mercury risks. By modeling an 'Alternate Mercury Control Scenario' using the EPA's own Integrated Planning Model (IPM), CATF demonstrates that more stringent mercury emission limits are cost-effective, providing substantial health benefits—specifically avoided premature deaths from PM2.5 exposure—that far outweigh the incremental costs to the power sector. The document further claims the EPA misled the public regarding its compliance with Executive Order 13045 concerning environmental health risks to children.

The report finds that Native American communities are more likely to live within a half-mile of oil and gas facilities than the general population of their encompassing states, leading to disproportionate exposure to methane, volatile organic compounds, and toxic air pollutants. This impact is exacerbated by high poverty rates and lack of health insurance, which limit housing options and access to medical care for conditions like asthma. Specifically, the analysis highlights the Navajo Nation, the Northern Ute (Uintah-Ouray), and the Fort Berthold Indian Reservation as areas of significant risk.

This December 2007 submission from the Chemicals and Allied Industries Association (CAIA) to the Department of Environmental Affairs and Tourism (DEAT) critiques the proposed minimum emission standards for listed activities. CAIA argues that the standards lack essential technical elements—such as averaging periods and compliance tolerances—and fail to follow the legally binding National Air Quality Framework. The association specifically opposes the adoption of European Union standards without considering the South African context, suggesting World Bank Standards as a more appropriate minimum baseline.

The Chemical and Allied Industries Association (CAIA) submitted this statement in August 2009 to express concerns regarding a draft Notice on atmospheric emission limits. CAIA argues that the proposed standards are overly stringent, lack a Regulatory Impact Assessment, and deviate from previous working documents. The association advocates for flexible compliance timeframes, the ability to apply for exemptions based on site-specific impact reports, and the adoption of realistic minimum emission standards that consider technical feasibility and overall environmental footprints.

A letter from the South African Petroleum Industry Association (SAPIA) to the Department of Environmental Affairs dated 30 April 2010, expressing concerns over the final 'List of Activities' published under the National Environmental Management: Air Quality Act, 2004. SAPIA argues that the final legislation deviates significantly from the draft version without adequate consultation or explanation, specifically regarding sulphur dioxide limits, timelines for existing refineries, and vapour recovery mandates.

This document is a revised submission by Business Unity South Africa (BUSA) providing detailed comments and proposed amendments to a draft Notice regarding activities resulting in atmospheric emissions. BUSA argues that the proposed emission limits and compliance timeframes are often technically and financially unfeasible, potentially harming the economic viability of the industrial and mining sectors during a period of manufacturing decline.

The report argues against doubling the SO2 emission limit, asserting that the government's rationale regarding water use and cost is flawed. It contends that Flue Gas Desulfurization (FGD) is more effective and not prohibitively water-intensive, while Dry Sorbent Injection (DSI) poses significant risks to particulate matter control, mercury emissions, and groundwater quality. The author recommends reducing the MES to 200 mg/Nm3 to align with international norms.

This fact sheet provides a detailed table and analysis of current pollutant emission rates (SO2, NOx, and PM10), estimated stack concentrations, and the emission limits requested by Eskom for 13 power stations. The document highlights inconsistencies in Eskom's reported data and argues that Eskom is effectively seeking exemptions from future Minimum Emission Standards (MES).

A formal request sent on 29 November 2016 by the Life After Coal Campaign and other environmental organisations to the South African Minister of Energy, seeking an extension for public comment on the Integrated Energy Plan (IEP) and the Integrated Resource Plan (IRP) Update and demanding the release of critical supporting documents.

The report assesses the 2019 Integrated Resource Plan for Electricity (IRP) proposal to add 1500 MW of new coal generation in South Africa. It finds that high-efficiency, low-emission (HELE) technologies cannot eliminate significant greenhouse gas emissions or air pollution. Specifically, ultra-supercritical efficiency is the highest feasible thermal cycle efficiency given IRP requirements, while carbon capture (CC) and gasification technologies (IGCC and UGCC) are deemed unproven and cost-prohibitive at scale. The report highlights that circulating fluidized bed technology emits two to ten times more nitrous oxide than pulverized coal technologies. Beyond plant emissions, the coal supply chain—including mining, transport, and ash disposal—creates unavoidable air, water, and waste impacts. Finally, the report asserts that bringing new coal generation online by 2023 is unreasonable due to the time required for design and procurement.

The Centre for Environmental Rights (CER) argues that South Africa's climate position for COP21 must be grounded in Constitutional obligations to protect human health and the environment. The CER contends that current investments in coal-fired power stations contradict national climate goals and that the state requires transparent, science-based emission regulations and enforcement to meet its legal duties.

The report argues that climate change causes profound adverse mental health implications for South Africans, exacerbating existing vulnerabilities caused by poverty and historical injustices. It highlights that exposures—such as natural disasters, water insecurity, and air pollution—lead to psychopathologies including anxiety, depression, and suicide. Children and future generations are identified as particularly vulnerable, facing psychological harms that can impair school performance and emotional well-being. The author further asserts that government decisions to continue developing coal capacity contribute to a sense of institutional betrayal and secondary trauma.

This responding statement, submitted by groundWork, argues against an appeal by Karpowership SA (PTY) Ltd regarding the Department of Forestry, Fisheries and the Environment's (DFFE) June 23, 2021, decision to refuse Environmental Authorisation (EA) for a gas-to-power project at the Port of Ngqura. groundWork contends that the project is neither necessary nor desirable, citing significant environmental risks, inadequate public participation, and the existence of more sustainable energy alternatives.

This research paper examines the legal framework and practical application of environmental authorizations for mining activities in South Africa, specifically focusing on the Mineral and Petroleum Resources Development Act (MPRDA) and the National Environmental Management Act (NEMA). The author argues that the current system of 'environmental authorizations' is often treated as a mere formality rather than a substantive tool for sustainable development, leading to inadequate environmental protection and a failure to properly integrate social and environmental costs into mining operations.

The authors argue that the current RED III methodology over-credits manure-based biomethane by using unrealistic baseline assumptions for manure management and incorrectly treating manure as a zero-emission waste feedstock. They call for a revision of the default avoided-emissions credit and a reassessment of system boundaries to include upstream livestock emissions.

The document identifies systemic failures in the World Trade Organisation's (WTO) internal processes, asserting that a lack of transparency and the exclusion of developing countries from decision-making undermine the organization's claim to be a "rules-based organisation". It details problems across general operations, pre-Ministerial preparations, and the conduct of Ministerial Conferences, specifically citing the "green room" process and "chair driven" negotiations as barriers to democracy. To remedy this, the authors propose a shift toward inclusive meetings, the cessation of "Mini Ministerials", and the establishment of a general committee of all members to serve as the primary decision-making forum during conferences.