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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of fugitive emissions from the oil and gas industry, pipeline transport, and abandoned mines, and criticizes the use of outdated global warming potential (GWP) metrics and low emission factors for coal mining.

This document is a response from Ember to a call for evidence regarding Greenhouse Gas Removal (GGR) technologies, specifically focusing on the risks, constraints, and costs associated with Bioenergy with Carbon Capture and Storage (BECCS).

This document is Ember's response to a UK government call for evidence on greenhouse gas removals (GGRs). It specifically critiques the reliance on Bioenergy with Carbon Capture and Storage (BECCS), arguing that the assumption of biomass carbon neutrality is flawed and that the land, environmental, and financial costs of scaling BECCS are prohibitive compared to other GGR methods or direct decarbonisation.

The Centre for Environmental Rights, on behalf of the Life After Coal Campaign, submitted a letter and technical report to the South African Minister of Environmental Affairs arguing that "clean coal" is a myth and a misnomer. The document asserts that coal-fired power generation is unsustainable due to environmental, health, and climate impacts, and advocates for a just transition to renewable energy sources like wind and solar to meet global climate targets.

This briefing, presented as a multigroup letter to Congress, argues against the revival of the Yucca Mountain high-level nuclear waste repository. The authors contend that the site is geologically unsuitable, the licensing process is flawed, and the project is technically and financially unworkable due to outdated design specifications and the need for unproven technology to meet safety standards.

A formal submission by the Vaal Environmental Justice Alliance (VEJA) and groundWork (gW) objecting to ArcelorMittal South Africa's (AMSA) application for postponements and alternative emission standards at its Vanderbijlpark Works facility.

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), representing several community and environmental groups, submitted preliminary representations opposing Eskom's applications to postpone compliance with Minimum Emission Standards (MES) for its coal-fired power stations. The CER argues that Eskom's applications are based on flawed atmospheric modelling, exaggerated compliance costs, and a failure to meet the legal requirements of the National Environmental Management: Air Quality Act (AQA) and the 2012 National Framework for Air Quality Management. The submission highlights that granting these postponements would increase pollution in declared Priority Areas and cause significant detrimental impacts on human health.

The Centre for Environmental Rights (CER), representing various community and environmental groups, submitted formal objections to Eskom's application to vary the Atmospheric Emission Licence (AEL) for the Kriel Power Station. The CER argues that the requested increase in particulate matter (PM) emissions would exacerbate poor air quality in the Highveld Priority Area, cause significant health impacts, and result from Eskom's own poor planning rather than a genuine emergency.

The Centre for Environmental Rights (CER), representing several community and environmental groups, submitted comments on August 23, 2013, regarding uMoya-NILU Consulting's Plan of Study (PoS). The PoS was designed to support Eskom's applications for exemptions and postponements of Minimum Emission Standards (MES) for its power stations. The CER argues that the PoS is too narrow in scope, fails to include critical pollutants like PM2.5, uses inappropriate modelling software for near-field impacts, and lacks a mechanism to verify model outputs against real-world ambient measurements.

Amory B. Lovins of the Rocky Mountain Institute provides a rebuttal to a response by Tromp et al. regarding hydrogen leakage rates. Lovins argues that the 10% to 20% leakage rate assumed by Tromp et al. is unsupported by evidence and technically implausible for commercial systems. He specifically disputes the claim that liquid hydrogen (LH2) boiloff from automotive tanks would contribute significantly to atmospheric emissions, asserting that such gases would be used as fuel or catalytically oxidized. Lovins further contends that the automotive industry is moving toward compressed gaseous hydrogen (GH2) over LH2 due to superior economics, safety, and weight, citing a concept SUV as evidence that high-pressure GH2 tanks can meet or exceed range benchmarks.

This research paper, submitted as a 'Brief Communication Arising' to Nature, argues that a United States hydrogen economy is practical and economically viable without the expansion of nuclear power. The author contends that fuel cells will accelerate the decline of nuclear power by providing cheaper energy services and that wind power is a more cost-effective method for hydrogen production via electrolysis than nuclear electricity.

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.

This document provides a technical critique by consultant Dr. Ranajit (Ron) Sahu regarding Eskom's applications to suspend compliance timeframes for Minimum Emissions Standards (MES) at various coal-fired power plants. The author argues that Eskom's justifications for delays—including plant decommissioning, water scarcity, and capital costs—are untenable or substantially inflated, and suggests alternative technologies to achieve emission reductions.

The Centre for Environmental Rights (CER) submitted comments on the revised draft Air Quality Management Plan (AQMP) for the Nkangala District Municipality (NDM). The CER argues that the plan is overly ambitious given the NDM's lack of capacity and resources, fails to align with the Highveld Priority Area (HPA) AQMP, and contains significant technical errors in its air quality modelling and data.

Dr. Ranajit (Ron) Sahu, acting as a consultant for the Centre for Environmental Rights, provides a technical critique of the South African Department of Environmental Affairs' (DEA) proposal to increase the Minimum Emission Standard (MES) for sulphur dioxide (SO2) from 500 mg/Nm3 to 1000 mg/Nm3 for coal-fired power plant stacks.

Ember's consultation response argues that Australia's Safeguard Mechanism must be significantly strengthened to address coal mine methane (CMM) emissions, which it claims are underestimated by 30-40%. The document advocates for a mandate against new coal mines, the adoption of a 20-year Global Warming Potential (GWP) for methane, and the implementation of strict industry benchmarks (1-3kg/tonne) to drive the closure of 'super-emitting' mines and the adoption of available capture technologies.