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Ember argues that the Boggabri coal mine's fugitive emissions are severely under-reported, using a self-led estimate that is 95 times lower than NSW state guidance. The submission warns that the proposed Modification 10, which involves mining deeper coal seams between 2033 and 2040, could result in Scope 1 emissions being 9 million tonnes higher than reported if state-recommended factors were used. Ember highlights a lack of assessment regarding how increased mining depth affects methane release and calls for a peer-reviewed assessment of pre-mine drainage mitigation before approval.

The Institute for Economic Justice submits that the Companies Amendment Bill 2021 introduces essential legal requirements for wage gap disclosure, binding votes on executive pay, and company ownership transparency to combat South Africa's severe socio-economic inequality.

The Centre for Environmental Rights (CER) submitted comments and proposed amendments to the Department of Mineral Resources and Energy regarding the draft Mine Community Resettlement Guidelines, 2019. The CER expressed concern that the public commenting period coincided with the festive season, which they argue compromised the public participation process by hindering engagement with clients and partners.

Natural Justice submitted comments to the National Environmental Management Authority (NEMA) on November 27, 2018, challenging the Environmental Impact Assessment (EIA) for a proposed salt works project by Al-Sherman Limited in Kilifi County. The submission argues that the EIA fails to adequately address risks to water sources, climate change impacts, local ecosystems, and community livelihoods, while also citing failures in the public participation process.

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.

The submission argues that current climate pledges are insufficient to limit warming to 2°C and warns that 'hot air' (surplus allowances) could allow developed countries to maintain business-as-usual emissions. It calls for a robust governance structure for Joint Implementation (JI) projects, focusing on transparency, environmental integrity, and the treatment of projects during the gap period.

Scientists for Global Responsibility (SGR) submits that GM field trials should be halted based on the precautionary principle. The submission highlights risks including the potential for GM genes to reduce soil fertility, the toxicity of GM pollen to insects, and the increased use of toxic herbicides. It further criticizes the lack of independent monitoring and data transparency in trials and provides evidence from North America regarding the pervasive and 'disastrous' contamination of organic crops and seeds by GM varieties.

The Chemical and Allied Industries Association (CAIA) submitted a May 2007 proposal to the Department of Environmental Affairs and Tourism (DEAT) regarding the implementation of Section 21 of the Air Quality Act. The submission critiques the proposed criteria for listing activities and emission standards, advocating for a risk-based approach, the avoidance of legislative duplication, and the use of national standards authorities for measurement methodologies.

This document is an interim consolidated industry submission regarding the draft schedule for implementing Section 21 of the Air Quality Act. It outlines industry positions on minimum emission values, compliance timeframes, monitoring approaches, and the management of fugitive emissions and upset conditions, emphasizing the need for standards to be based on the Best Practicable Environmental Option (BPEO) principle within the South African context.

A submission by Sasol to Working Group 4 and a Subcommittee dated 9 March 2009 regarding proposed emission standards and the categorization of waste incinerators under the draft Section 21 of the National Environmental Management: Air Quality Act in South Africa.

A June 2012 submission by the Natref refinery to the South African Department of Environmental Affairs (DEA) regarding proposed Minimum Emission Standards (MES). Natref argues that inflexible national point source emission standards are impractical for existing facilities and proposes a 'bubble' approach to emissions management to ensure socio-economic sustainability and energy security.

This October 2012 submission from the Natref refinery to the South African Department of Environmental Affairs (DEA) argues that the proposed Minimum Emission Standards (MES) are technically and socio-economically unsustainable for existing inland refineries. Natref advocates for a "bubble" approach to emissions management rather than a point-source approach and requests separate, less stringent limits for existing facilities compared to new plants.

This document is a December 2012 submission by Natref to the Department of Environmental Affairs (DEA) regarding the draft Notice of Minimum Emission Standards (MES) under the National Environmental Management: Air Quality Act, 2004. Natref, South Africa's only inland oil refinery, argues that the proposed point-source emission limits for sulphur dioxide (SO2), particulate matter (PM), and nitrogen oxides (NOx) are technically and economically unfeasible due to its unique inland location, fuel oil requirements, and space constraints. The company advocates for a "bubble" approach to emissions management and requests differentiated limits based on fuel type to maintain business sustainability and ensure the success of the Clean Fuels II project.

Sasol argues that retrofitting old plants to meet new emission standards is often technically impossible due to space and configuration constraints, and economically unjustifiable given the negligible impact on ambient air quality in some areas. The company highlights conflicts between air quality standards and national energy efficiency and waste strategies, while calling for extended compliance timelines and greater regulatory certainty across national, provincial, and local government tiers.

The South African Petroleum Industry Association (SAPIA) submitted a set of comments and proposals to the Department of Environmental Affairs (DEA) on December 23, 2012, regarding the regulation of atmospheric emissions. The submission focuses on refining definitions, reporting requirements, compliance timeframes, and specific emission standards for combustion installations and petroleum product storage.

A submission from Eskom to the South African government regarding proposed minimum emission standards for combustion installations, arguing for practical limits based on technological, resource, and cost constraints.

In a submission to the Parliament Portfolio Committee on Water and Environmental Affairs dated 12 April 2013, Eskom expresses concerns that full compliance with the Minimum Emission Standards (MES) for Listed Activities under the National Environmental Management: Air Quality Act, 2004, would threaten energy security and increase electricity tariffs. While supporting the act in general, Eskom argues that the standards ignore local scientific evidence and resource constraints, specifically regarding water availability and capital costs.

A cover letter from the Centre for Environmental Rights (CER) submitting formal comments on the draft Air Quality Management Plan (AQMP) and Air Quality Management By-law for the Nkangala District Municipality on behalf of the Highveld Environmental Justice Network, groundWork, and Earthlife Africa, Johannesburg.

Business Unity South Africa (BUSA) submitted a statement in August 2009 expressing concerns over proposed minimum emission limits. BUSA argues that the standards are unjustifiably stringent, deviate from previous industry discussions during the SABS process, and fail to account for the operational realities of upset conditions, potentially harming the competitiveness of South African manufacturing and exports.

The EEB and ClientEarth submission to ECHA argues for a comprehensive restriction on intentionally added microplastics, warning that ECHA may prematurely narrow the scope of restrictions through unjustified derogations. The authors advocate for treating microplastics as non-threshold substances, similar to vPvB or PBT substances, due to their persistence and ability to bioaccumulate. They highlight the role of microplastics in transporting persistent organic pollutants (POPs) and leaching endocrine-disrupting additives into the environment and human body. The submission supports a broad definition of microplastics that includes liquid polymers and compostable bioplastics, and emphasizes the need to consider the high exposure risks associated with nanoplastics.