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Supplementary SAHRC Submission: Just Transition in the Food System Group
This supplementary submission by the Just Transition in the Food System Group to the South African Human Rights Commission (SAHRC) argues that food insecurity in South Africa is a result of structural conditions and policy failures. It advocates for a rights-based food system transition focusing on agroecology, a Universal Basic Income Grant, improved land access for women, and aligned state budgeting to fulfill the constitutional right to food.
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Document type: Report
Submission to the Clean Energy Regulator: Enhancing Method 2 for Coal Mine Emissions Reporting
This submission by Ember to the Clean Energy Regulator argues that 'Method 2' for reporting fugitive methane emissions from Australian coal mines is scientifically inadequate and leads to significant under-reporting. The document highlights a growing gap between increasing coal production and stagnant or declining reported emissions, particularly in New South Wales. Ember recommends urgent reforms, including mandated regular updates to emission factors, increased borehole density, independent third-party verification, and the integration of satellite-based atmospheric monitoring to ensure the integrity of Australia's national emissions inventory.
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Document type: Report
Submission: Proposed Amendments to the EIA Regulations in South Africa
Natural Justice submitted a response to the South African government's 2024 proposed amendments to the Environmental Impact Assessment (EIA) regulations, advocating for thorough assessments of high-impact activities, enhanced public participation, and alignment with climate and conservation goals.
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Document type: Statement
Boggabri Coal Mine Modification 10 EPBC ref 2024/09887 Submission to Australia’s Department of Climate Change, Energy, Environment and Water on the proposed modification of Boggabri coal mine and the potential for it to have a significant, under evaluated impact on fugitive emissions increases
Ember submitted a statement to Australia's Department of Climate Change, Energy, Environment and Water arguing that the Boggabri Coal Mine's Modification 10 proposal significantly underestimates fugitive emissions. Ember contends that the mine uses an unverified, decade-old emissions factor that is 95 times lower than state guidance, potentially under-reporting Scope 1 emissions by millions of tonnes, especially as the mine seeks to operate at greater depths.
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Document type: Statement
Submission to the Review of Australia’s Coal Mine Waste Gas method
This submission by Ember to the Federal Department of Climate Change, Energy, the Environment and Water (DCCEEW) argues for the extension and expansion of Australia's Coal Mine Waste Gas (CMWG) method beyond 2025. Ember recommends extending the methodology to include open-cut mines and improving measurement and verification frameworks to accelerate the decarbonisation of the coal sector.
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Document type: Report
Submission to Australia’s National Greenhouse and Energy Reporting Scheme 2023 Proposed Amendments
Ember's submission to the Australian government argues that the National Greenhouse and Energy Reporting Scheme (NGERS) relies on inadequate state-based emissions factors for Queensland open cut coal mines. The document recommends phasing out 'Method 1' in favor of direct measurement and multi-input models to accurately capture methane variability and super-emitting events.
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Document type: Report
Submission to the UNFCCC Global Stocktake first technical call
This submission by the Global Climate and Health Alliance (GCHA) and the Health and Climate Network (HCN) to the UNFCCC Global Stocktake first technical call argues that health is a prerequisite for the successful implementation of the Paris Agreement. The document advocates for the integration of health metrics and outcomes across mitigation, adaptation, finance, and loss and damage frameworks to maximize co-benefits and protect vulnerable populations.
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Document type: Report
Ember’s submission to the Environmental Audit Committee RE: Call for Evidence - Technological Innovations and Climate Change: Negative Emissions Technologies
Ember's submission to the Environmental Audit Committee expresses concern that current mainstream Bioenergy with Carbon Capture and Storage (BECCS), specifically the model proposed at the Drax power station, may fail to deliver genuine negative emissions due to the carbon impact of burning wood for power.
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Document type: Statement
cape-submission-for-bill-c-230-376d3ff112d8aac0.pdf
The Canadian Association of Physicians for the Environment (CAPE) submitted a statement to the Standing Committee on Environment and Sustainable Development urging the passage of Bill C-230, which aims to develop a national strategy to redress environmental racism.
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Document type: Statement
SUBMISSION: CULTURAL RIGHTS AND CLIMATE CHANGE
This submission by Natural Justice to the UN Special Rapporteur in the Field of Cultural Rights details the impacts of climate change on indigenous peoples and local communities in Africa. It highlights how environmental shifts and land-use changes threaten bio-cultural resources and traditional knowledge, while presenting 'Community Protocols' as a tool for adaptation and the protection of cultural rights. The document also outlines the severe risks faced by cultural and environmental rights defenders in Africa, including violence, criminalization, and land grabbing.
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Document type: Statement
SUBMISSIONS ON THE DRAFT MINE COMMUNITY RESETTLEMENT GUIDELINES, 2019
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.
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Document type: Statement
SUBMISSION OF COMMENTS TO THE ENVIRONMENTAL IMPACT ASSESSMENT STUDY REPORT FOR THE PROPOSED SALT WORKS IN A SECTION OF LAND PARCEL L.R. NO. 13536, MARERENI, KILIFI COUNTY
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.
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Document type: Statement
ESKOM’S APPLICATION FOR EXEMPTION FROM MINIMUM EMISSION STANDARDS AND POSTPONEMENT OF THE MINIMUM EMISSION STANDARDS TIMEFRAMES FOR ESKOM POWER STATIONS
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.
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Document type: Statement
PROPOSED AMENDMENT TO THE MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002: SUBMISSIONS BY 13 NON-‐GOVERNMENT ORGANISATIONS REGARDING ENVIRONMENTAL REGULATION OF PROSPECTING, RECONNAISSANCE, EXPLORATION AND MINING
A submission by 13 non-governmental organisations, coordinated by the Centre for Environmental Rights, addressed to the Minister of Mineral Resources regarding proposed amendments to the Mineral and Petroleum Resources Development Act, 2002 (MPRDA). The document argues that the current environmental regulatory regime for mining is inferior to that of other industrial sectors and calls for the integration of mining regulation under the National Environmental Management Act (NEMA) to ensure better environmental protection, public participation, and enforcement.
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Document type: Statement
SUBMISSION OF NON-DISPUTING PARTIES
This document is a submission by non-disputing parties (Bluewater Network, Communities for a Better Environment, and the Center for International Environmental Law) to an arbitration tribunal regarding a dispute between Methanex Corporation and the United States. The submission argues that California's ban on the gasoline additive MTBE was a legitimate exercise of government power to protect public health and the environment, and should therefore be granted substantial deference under NAFTA and international law.
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Document type: Report
2014-05-30-fa10-caia-submission-may-2007-01aa857987c9306f.pdf
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.
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Document type: Statement
2014-05-30-fa28-interim-consolidated-industry-submission-c091da9545fc31c2.pdf
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.
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Document type: Report
2014-05-30-fa29-sasol-letter-to-wg4-9-03-2009-3afa478c91947a8b.pdf
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.
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Document type: Statement
2014-05-30-fa46-natref-submission-05-2012-018e25d4b2c23688.pdf
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.
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Document type: Report
2014-05-30-fa52-natref-submission-to-dea-10-2012-530e4ff6e1ac4773.pdf
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.
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Document type: Report