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sep-2016-202025-20--20ucs-20endangerment-20finding-20letter-751397c0c3cf781a.pdf
The Union of Concerned Scientists and a broad coalition of experts argue that the EPA's proposal to repeal the 2009 Endangerment Finding is contrary to scientific evidence and the public interest. They assert that human-caused climate change is indisputable and causes severe harms to public health, the economy, and the environment. The authors specifically criticize the EPA's reliance on a Department of Energy report they describe as unscientific and inaccurate, while urging the agency to maintain regulations on heat-trapping emissions to meet global climate goals.
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Document type: Statement
SUBMISSIONS ON ESKOM’S APPLICATION FOR EXEMPTION IN TERMS OF SECTION 59 WITH THE MINIMUM EMISSION STANDARDS FOR 8 OF ITS COAL-FIRED POWER STATIONS
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.
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Document type: Statement
ESKOM’S INTENDED APPLICATIONS FOR EXEMPTION FROM COMPLIANCE WITH THE MINIMUM EMISSION STANDARDS UNDER THE NATIONAL ENVIRONMENTAL MANAGEMENT: AIR QUALITY ACT 39 OF 2004
The Life After Coal campaign (LAC) has formally objected to Eskom's attempts to secure exemptions from the Minimum Emission Standards (MES), asserting that such exemptions are prohibited under section 59 of the Air Quality Act (AQA). The LAC argues that Eskom, as South Africa's largest air polluter, cannot be legally exempt from national emission standards, and that granting such exemptions would undermine the rule of law, harm public health, and set a dangerous precedent for future climate change legislation.
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Document type: Statement
THE PROPOSED MUSINA-MAKHADO SPECIAL ECONOMIC ZONE INFRASTRUCTURE, LOCATED WITHIN THE VHEMBE DISTRICT MUNICIPALITY OF THE LIMPOPO PROVINCE
The Centre for Environmental Rights (CER), representing groundWork and Earthlife Africa, has formally alerted the Department of Environment, Forestry and Fisheries (DEFF) to critical flaws in the EIA process for the Musina-Makhado Special Economic Zone (EMSEZ) in Limpopo. The CER argues that the project's potential for 'astronomical' environmental, health, and climate impacts—including the proposed 3,300 MW thermal power plant—makes it a matter of national importance. They contend that the Limpopo Department of Economic Development, Environment and Tourism (LEDET) is an inappropriate competent authority and that the Minister of Environment, Forestry and Fisheries should instead oversee the process. The CER specifically highlights risks to water-stressed regions, air quality in priority areas, and South Africa's international climate commitments under the Paris Agreement, requesting that the scoping process be restarted and preceded by a strategic environmental assessment (SEA).
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Document type: Statement
industry-favors-during-shutdown_1-25-19-4bf1950e4a0dfa16.pdf
A coalition of environmental organizations argues that the US government prioritized industry interests over public resources during the 2018-2019 shutdown by continuing oil and gas permitting, offshore drilling planning, and logging projects while essential public services and environmental protections were suspended.
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Document type: Statement
Final Notice of Objection to Re-evaluation Decision RVD2017-01, Glyphosate, April 28, 2017
The Canadian Association of Physicians for the Environment and other organizations are calling for an independent review of the PMRA's glyphosate re-evaluation decision (RVD2017-01). They argue that internal Monsanto documents, revealed during California litigation, show the company ghostwrote scientific studies and suppressed evidence of cancer risks—studies that the PMRA relied upon for its determination that glyphosate is unlikely to pose a human cancer risk. The authors also claim the PMRA failed to consider evidence regarding monarch decline, microbiomes, and the inefficiency of buffer zones as risk management strategies.
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Document type: Statement
Final Notice of Objection to Re-evaluation Decision RVD2017-01, Glyphosate, April 28 2017
The document argues that the PMRA's re-evaluation of glyphosate is flawed due to the dismissal of critical evidence concerning ecological risks, human health impacts, and the inefficiency of proposed risk management strategies.
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Document type: Report
ADDITIONAL SUBMISSIONS REGARDING THE VARIATION OF THE ATMOSPHERIC EMISSION LICENCE FOR ESKOM’S KRIEL POWER STATION
The Centre for Environmental Rights (CER), representing several community and environmental groups, submitted a response to the Nkangala District Municipality opposing Eskom's application to vary the atmospheric emission licence for the Kriel Power Station. The CER argues that the variation would permit increased emissions of particulate matter (PM10) and mercury, leading to significant public health risks and economic costs, while challenging Eskom's dispersion modelling and cost calculations for abatement technology.
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Document type: Statement
gw-objection-karpowerships-saldanha-nersa-commissioned-4.08.2021-f56e19364879c239.pdf
This document is a formal objection submitted by the Centre for Environmental Rights (CER) to the National Energy Regulator of South Africa (NERSA) regarding the proposed use of Karpowerships in Saldanha Bay. The CER argues that the project is inconsistent with South Africa's climate commitments, lacks transparency, and fails to consider cheaper, cleaner energy alternatives.
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Document type: Statement