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The Centre for Environmental Rights (CER) submitted a statement to the Department of Environmental Affairs (DEA) opposing Eskom's applications to postpone compliance with Minimum Emission Standards (MES). The CER argues that Eskom failed to provide required health impact assessments and future compliance plans, while monitoring data indicates that Eskom's emissions cause frequent, year-round exceedances of air quality guidelines, contributing to significant regional health risks.

This document consists of a formal submission by the Centre for Environmental Rights (CER) and an accompanying independent peer review by Carin Bosman Sustainable Solutions (CBSS). It critiques the Integrated Water Use Licence Application (IWULA) Report prepared by Jones and Wagner for KiPower's proposed 600 MW coal-fired power station in Mpumalanga, South Africa. The CER and CBSS conclude that the IWULA is 'Inadequate' due to significant procedural and substantive failures, including the absence of a practical Integrated Water and Waste Management Plan (IWWMP) Action Plan and a failure to adequately assess impacts on groundwater and other water users.

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), acting for several environmental justice organisations, submitted comments on the Department of Environmental Affairs' (DEA) Draft Air Quality Offset Policy. The CER and its clients oppose the use of offsets in principle, arguing they serve as a "cheap option to avoid compliance" with emission standards and could undermine the constitutional right to a healthy environment. The submission highlights significant gaps in the draft policy, including a lack of clear criteria for determining offsets, poor institutional capacity for monitoring and enforcement, and failure to address equity and distributional effects.

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.

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.

A joint submission by five environmental organisations to the Portfolio Committee on Mineral Resources regarding the Mineral and Petroleum Resources Amendment Bill [B15-2013]. The submission argues that the Bill and the principal Act fail to protect constitutional rights to fair administrative action and access to information for parties affected by mining.

A joint submission by several environmental organisations to the Portfolio Committee on Mineral Resources arguing against the MPRDA Amendment Bill's proposal to transfer environmental authorisation and enforcement powers for mining activities to the Department of Mineral Resources (DMR). The authors contend that the DMR lacks the human resource capacity, budget, and track record to implement the National Environmental Management Act (NEMA) and that such a transfer creates an inherent conflict of interest between promoting mining and protecting the environment.

This joint submission by several environmental organisations and a consultant to the Portfolio Committee on Mineral Resources addresses the Mineral and Petroleum Resources Development Amendment Bill [B15-2013]. The authors focus on the issues of mine closure, rehabilitation, and financial provision, specifically arguing against a proposed 20-year limit on the retention of funds for latent environmental impacts and calling for better alignment between the MPRDA and the National Environmental Management Act (NEMA).

The Centre for Environmental Rights (CER), representing groundWork, the South Durban Community Environmental Alliance (SDCEA), and the Vaal Environmental Justice Alliance (VEJA), submitted comments on 16 April 2013 regarding the draft 2012 National Framework for Air Quality Management in South Africa. The CER argues that the Department of Environmental Affairs (DEA) failed to follow prescribed review processes, ignored legislative obligations from the 2007 Framework, and provided insufficient support to municipalities for air quality management.

The Centre for Environmental Rights (CER) submitted comments on the Mineral and Petroleum Resources Development Amendment Bill, 2012, arguing that while the application of the National Environmental Management Act (NEMA) to mining is welcome, the Bill fails to adequately protect community rights, ensure transparency, or establish a fair penalty system.

The Centre for Environmental Rights (CER) submitted comments on the Draft Second Edition of the National Water Resource Strategy (draft NWRS2) to the Portfolio Committee on Water and Environmental Affairs. The CER evaluates the draft against its own 2012 report, 'Stop Treading Water', highlighting areas of alignment and critical gaps in governance, institutional stability, and regulatory enforcement within South Africa's water sector.

The Centre for Environmental Rights (CER), acting for groundWork and the Vaal Environmental Justice Alliance (VEJA), submitted a statement to the Department of Environmental Affairs on 31 January 2012. The document objects to proposed amendments to the National Environmental Management: Air Quality Act, 2004’s list of activities resulting in atmospheric emissions, arguing that the changes generally relax emission limits, extend compliance time-frames, and were developed through a non-transparent process that favored industry representatives over affected communities.

The Centre for Environmental Rights, representing groundWork, the South Durban Community Environmental Alliance (SDCEA), and the Vaal Environmental Justice Alliance (VEJA), submitted a statement to the Portfolio Committee on Water and Environmental Affairs regarding the South African Weather Service Amendment Bill, 2011. The submission expresses grave concerns that the Bill's proposed criminalization of issuing air pollution-related warnings without permission would undermine public health, freedom of speech, and existing environmental governance frameworks under the National Environmental Management Act (NEMA).

This submission by Fundación Pachamama and the International Institute for Sustainable Development (IISD) argues that the arbitration tribunal in the case of Chevron Corporation and Texaco Petroleum Company v. Republic of Ecuador lacks jurisdiction and that the claims are non-justiciable. The Amici contend that Chevron is attempting to use an investor-State tribunal to interfere with and terminate an ongoing domestic civil law case (the Lago Agrio litigation) in Ecuador, which would violate the rights of private plaintiffs, including indigenous peoples, to a fair judicial process.

This joint post-hearing submission by several amici curiae (including the International Institute for Sustainable Development) addresses the legal status of environmental measures under the police powers exclusion from expropriation in the NAFTA Chapter 11 arbitration between Methanex Corporation and the United States.

A cover letter dated 26 April 2017 from Namane Generation (Pty) Ltd to the Minister of Environmental Affairs, submitting a responding statement against an appeal filed by the Centre for Environmental Rights (CER) regarding the environmental authorisation for the Namane Generation IPP and associated infrastructure.

The Centre for Environmental Rights (CER), acting for the Highveld Environmental Justice Network (HEJN), groundWork (gW), and Earthlife Africa (ELA), submitted preliminary objections and recommendations regarding the draft Air Quality Management Plan (AQMP) and draft Air Quality Management By-laws for the Nkangala District Municipality (NDM). The CER argues that the public participation process was procedurally unfair due to insufficient notice and comment periods. Substantively, the CER identifies critical gaps in the draft AQMP, including a lack of enforcement strategies, insufficient technical capacity within the NDM, and misalignment with the Highveld Priority Area (HPA) goals. The CER also proposes significant amendments to the draft by-laws to strengthen dust control, clarify authorization procedures, and ensure stricter local emission standards.

The Centre for Environmental Rights (CER) provides detailed legal and technical submissions on the draft Air Quality Management By-law for the Ngkawi District Municipality (NDM). The CER recommends aligning the by-laws with national legislation, such as the National Environmental Management: Air Quality Act (AQA) and the National Environmental Management Act (NEMA), and suggests stricter local emission and dust standards to protect human health, particularly given the area's location within a High Priority Area (HPA).

This document is a replying submission by Atha-Africa Ventures (Pty) Ltd to the Director-General of the Department of Mineral Resources. It responds to an administrative appeal lodged by a coalition of environmental organisations against the approval of the Environmental Management Programme (EMP) for the Yzermyn Underground Coal Mine Project.