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The Centre for Environmental Rights (CER), on behalf of groundWork and Earthlife Africa, submits a formal objection to Eskom's application for exemptions from Minimum Emission Standards (MES) for eight coal-fired power stations under section 59 of the Air Quality Act (AQA). The submission argues that these exemptions violate the constitutional right to a healthy environment, particularly for residents in Priority Areas, and that Eskom has failed to justify its 14-year delay in achieving compliance.

The Centre for Environmental Rights (CER), on behalf of the Life After Coal (LAC) coalition, submitted comments on the Gas Amendment Bill [B – 2023], arguing that accelerating gas infrastructure is irrational given the climate emergency and South Africa's extreme vulnerability to climate change. The submission criticizes the Bill for inadequate public consultation processes, lack of transparency regarding confidential information, and a failure to align with international climate targets such as the IPCC's 1.5°C benchmark.

This submission by the Centre for Environmental Rights (CER), on behalf of groundWork and Earthlife Africa, opposes Eskom's applications for the postponement and suspension of Minimum Emission Standards (MES) compliance. The document argues that Eskom's failure to comply with air quality laws violates constitutional rights to health and a safe environment, particularly in the Highveld Priority Area. It provides evidence of extensive emission exceedances, high emission intensity compared to international standards, and severe public health impacts, while asserting that abatement technologies are technically and economically feasible.

The Centre for Environmental Rights (CER) submitted comments on the draft National Water Resources Strategy 3 (NWRS-3) on 28 October 2022. The submission argues that the strategy must move beyond treating climate change as a future uncertainty and instead implement binding regulations to protect water security. The CER emphasizes the need for legal protection of Strategic Water Source Areas (SWSAs), strengthened compliance monitoring and enforcement (CME), increased transparency in water resource information, and a precautionary approach to unconventional oil and gas exploration due to risks of water contamination and greenhouse gas emissions.

Natural Justice submitted a statement expressing deep concern that the South African Climate Change Bill fails to address the urgency of the climate crisis, lacks ambitious emission targets, and omits necessary funding and capacity-building for implementation.

The Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, represented by the Centre for Environmental Rights, groundWork, and Earthlife Africa, submitted comments on the Climate Change Bill, 2022. The submission argues that the Bill is insufficient to address the climate emergency and lacks the urgency, ambition, and enforcement mechanisms necessary to meet South Africa's international obligations under the Paris Agreement and protect constitutional rights.

Natural Justice (NJ) submitted a formal objection on 31 January 2022 to proposed amendments to the s24H Registration Authority Regulations, 2016 under the National Environmental Management Act (NEMA). NJ argues that requiring a registered Environmental Assessment Practitioner (EAP) to handle appeals and certain submissions would create prohibitive financial barriers for communities, effectively barring them from the appeals process and subsequent judicial review.

Natural Justice (NJ) submitted a critique of the South African Department of Mineral Resources and Energy's (DMRE) Gas Master Plan Base Case report on January 31, 2022. NJ argues that the plan is incompatible with climate commitments, lacks sufficient risk analysis regarding financial and environmental costs, and fails to provide adequate mechanisms for public participation and community compensation.

The Centre for Environmental Rights (CER), on behalf of itself and groundWork, submitted comments on the draft Gas Amendment Bill [B9 – 2020] to the Portfolio Committee on Mineral Resources and Energy. The CER argues that the Bill fails to account for the climate emergency, lacks adequate public consultation and access to information, and irregularly encroaches upon environmental regulatory powers reserved for the Minister of Forestry, Fisheries and Environment.

Natural Justice (NJ), a non-profit organization, submitted comments on the draft Expropriation Bill, 2020, to the South African Department of Public Works. While welcoming the Bill's goal to replace the Expropriation Act of 1975 and allow for expropriation without compensation to redress historical land imbalances, NJ argues the draft is too state-centric, lacks climate change considerations, and fails to provide sufficient mechanisms for public oversight and the protection of vulnerable land rights holders.

This document is a practice note filed on 7 August 2020 by the legal representatives of Atha-Africa Ventures (Pty) Ltd (the Second Respondent) in the High Court of South Africa, Gauteng Division, Pretoria. It outlines the Second Respondent's position regarding a special appeal brought by the Endangered Wildlife Trust and the Federation for a Sustainable Environment against a Water Tribunal decision that confirmed the granting of a Water Use License for the Underground Yzermyn Coalmining Project.

Natural Justice submitted comments on the Statute Law (Miscellaneous Amendments) Bill, 2020, opposing the removal of Council of Governors nominees from the boards of the Energy Petroleum Regulatory Authority and the Rural Electrification and Renewable Energy Corporation.

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.

The Centre for Environmental Rights (CER) submitted preliminary comments on the National Environmental Management Laws Amendment Bill [B 14D-2017], specifically focusing on the National Environmental Management: Air Quality Act, 2004 (NEMAQA) and the National Environmental Management: Waste Act, 2008. The CER requested an extension until 13 February 2020 to provide further submissions on the National Environmental Management Act, 1998 (NEMA) and mining matters, citing the festive season closure of their offices.

This document contains legal submissions by a coalition of eight environmental organisations, represented by the Centre for Environmental Rights, appealing a decision by the Gert Sibande District Joint Municipal Planning Tribunal. The appeal seeks to revoke the approval of a land-use change application by Atha-Africa Ventures (Pty) Ltd to enable the construction of the Yzermyn Underground Coal Mine on Portion 1 of the farm Yzermyn 96 HT, arguing that the decision is unlawful, environmentally catastrophic, and contrary to national water security interests.

This amicus curiae submission, filed by Alburnus Maior, Centrul Independent pentru Dezvoltarea Resurselor de Mediu (ICDER), and Greenpeace Romania, argues that Gabriel Resources Ltd. failed to meet investor responsibilities and legal requirements regarding a proposed gold mine in Roșia Montană, Romania. The document contends that the company lacked due diligence on project feasibility, violated human rights related to adequate housing, and failed to obtain necessary environmental and archaeological permits under Romanian and EU law.

The Centre for Environmental Rights (CER), representing several environmental justice organisations, submitted provisional comments on June 29, 2018, regarding the Department of Environmental Affairs' (DEA) proposed amendments to the 2012 National Framework for Air Quality Management in South Africa. The CER argues that the public consultation process was inadequate and that the draft Framework fails to address systemic failures in air quality monitoring, enforcement, and the achievement of previous targets.

The Centre for Environmental Rights, representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted representations on June 25, 2018, regarding proposed amendments to the List of Activities resulting in atmospheric emissions. While supporting the elimination of 'rolling postponements' for minimum emission standards (MES), the submission argues for stricter requirements for once-off suspensions, greater transparency in application documents, and a more robust public participation process.

The Centre for Environmental Rights (CER), representing various non-governmental and community-based organisations, submitted comments to the Department of Environmental Affairs (DEA) regarding the 2018 Draft Amendments to the National Dust Control Regulations 2013. The CER argues that the draft regulations remain inadequate for protecting human health and the environment, particularly for mining-affected communities, and calls for more rigorous enforcement, better monitoring methods, and the inclusion of specific health-related analyses for toxic dust.

The Centre for Environmental Rights (CER) submitted comments to the South African Department of Environmental Affairs (DEA) on June 15, 2018, regarding the operationalisation of the post-2020 mitigation system. The CER advocates for greater transparency in greenhouse gas (GHG) reporting, opposes the use of historical emissions for carbon budgeting, and argues against the inclusion of new coal-fired power stations in national energy plans.