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APPEAL IN TERMS OF S43 OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, OF THE PROVISIONAL AEL ISSUED TO THABAMETSI POWER COMPANY (PTY) LTD - AEL/LP/TPC/09/10/2018
This document is a cover letter from the Centre for Environmental Rights, sent on 30 October 2019 to the Minister of Environment, Forestry and Fisheries, submitting an appeal on behalf of Earthlife Africa and groundWork. The appeal seeks to set aside a provisional atmospheric emission licence (PAEL) issued to Thabametsi Power Company (Pty) Ltd.
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Document type: Statement
Scientists letter to EPA
The document is a formal letter from a multidisciplinary group of experts urging the EPA to maintain strong fuel efficiency and emissions standards rather than adopting the proposed SAFE Vehicles Rule, which they argue would harm the climate, public health, and the economy.
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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
EPA stops collecting data on pollutants released by farms
The EPA, under administrator Andrew Wheeler, stopped collecting data on ammonia and hydrogen sulfide emissions from large concentrated animal feeding operations (CAFOs) in June 2019. This policy, which faced opposition from 99 percent of 87,473 public comments, removes a reporting requirement for farms emitting 100 pounds or more of these pollutants daily. The document asserts that this lack of data hinders the ability of emergency responders and communities—particularly low-income communities and communities of color—to protect themselves from health risks associated with CAFOs, such as respiratory issues and elevated blood pressure.
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Document type: Fact sheet
THE COST OF AVAILABLE POLLUTION ABATEMENT TECHNOLOGIES REQUIRED TO MEET MINIMUM EMISSION STANDARDS FOR SULPHUR DIOXIDE (SO2)
The Centre for Environmental Rights (CER) asserts that South Africa's Minimum Emission Standards (MES) for sulphur dioxide (SO2) are already weak compared to other developing nations and should be strictly enforced. The CER disputes claims by Eskom and Sasol that compliance is too expensive, citing expert analysis that suggests Eskom's capital cost estimates for flue gas desulphurisation (FGD) and low NOx burners are significantly inflated. The document highlights that failure to comply with the MES could lead to approximately 16,000 avoidable premature deaths, while doubling the SO2 limit to 1000mg/Nm3 would cause an additional 3,300 premature deaths. It recommends the use of FGD as the best available technology for long-term operation and dry sorbent injection (DSI) only for plants nearing decommissioning.
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Document type: Statement
Driving A Shared, Electric, Autonomous Mobility Future
The report analyzes the transition toward electric vehicles (EVs), shared mobility, and autonomous vehicles (AVs) in China, India, and the United States. It argues that while battery costs will likely lead to price parity with combustion vehicles within 5–10 years, coordinated policies—such as China's mix of rewards and punishments or India's focus on high-utilization vehicles—are necessary to accelerate adoption. The authors emphasize that shared mobility and AVs must be electrified and pooled to avoid increasing congestion and pollution, and suggest that China and India may leapfrog the US model of private car ownership due to rapid urbanization.
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Document type: Report
The cash cow has stopped giving: Are Germany’s lignite plants now worthless?
The report finds that German lignite plants became significantly unprofitable in the first half of 2019, with the entire fleet losing €664 million. Old units (pre-1990) were hardest hit, with gross profits falling 62% to €188 million. The analysis suggests that 24/7 baseload operation is no longer economic and predicts a €1.8 billion loss for old units between 2020 and 2022. Consequently, the author recommends that the German government push for faster closures, reject excessive compensation claims, and implement a minimum carbon price to prevent future profitability.
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Document type: Report
Review of Dr. Andrew Gray’s “AIR QUALITY IMPACTS AND HEALTH EFFECTS DUE TO LARGE STATIONARY SOURCE EMISSIONS IN AND AROUND SOUTH AFRICA’S MPUMALANGA HIGHVELD PRIORITY AREA (HPA)” (June2019)
Professor Peter Orris reviews Dr. Andrew Gray's modeling of emissions from 12 coal-fired power plants, a Synfuels facility, and a NatRef refinery in South Africa. Orris concludes that these facilities create a significant public health hazard, contributing to hundreds of premature deaths annually via PM2.5 exposure. He notes that while implementing the 2020 Minimum Emission Standards (MES) would significantly reduce PM2.5-related deaths, it would not eliminate all WHO guideline exceedances for SO2 and NO2. The review emphasizes the vulnerability of children and the elderly at sensitive sites like schools and hospitals.
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Document type: Report
IN THE HIGH COURT OF SOUTH AFRICA GAUTENG DIVISION, PRETORIA
This document is a Rule 16A notice filed in the High Court of South Africa, Gauteng Division, Pretoria, in June 2019. It outlines the constitutional issues raised by applicants—including GroundWork and the Vukani Environmental Justice Alliance—regarding air pollution in the Highveld Priority Area and the failure of the Minister of Environmental Affairs to establish regulations to implement the Highveld Priority Area Air Quality Management Plan.
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Document type: Statement
PRE-ISSUANCE VERIFICATION REPORT
Vigeo Eiris conducted a limited assurance procedure on the Republic of Chile's 2019 first Green Bond, concluding that it conforms in all material respects to the Climate Bonds Standard (CBS) version 2.1. The bond's proceeds are intended for 14 eligible green expenditures across solar energy, low carbon land transport, green buildings, and water management. The verification confirmed the existence of a documented decision-making process led by a Green Bond Committee and verified that the nominated projects meet specific sector criteria, such as a 30% carbon reduction target for buildings and a limit of 15% non-renewable electricity for solar projects. The report also validates the internal processes for tracking proceeds and the commitment to post-issuance compliance reviews.
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Document type: Report
Assessing reduction in annual and daily fine particulate matter impact in Paris
The study analyzes PM2.5 concentrations in Paris and the Île-de-France region from 2009 to 2018, finding that reductions in annual averages and high-concentration days were primarily driven by local emission decreases. However, regional transport remains a significant factor, contributing up to 70% of annual PM2.5 at urban background sites, suggesting that regional emission reductions are necessary to meet WHO guidelines.
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Document type: Research paper
Air quality in Germany – evidence hearing on the health impacts of air pollution
The Higher Administrative Court of Münster scheduled a two-day evidence hearing on 9-10 May 2019 featuring science and health experts to resolve debates over air quality rules and diesel restrictions in Germany. This follows legal actions in 35 German cities supported by ClientEarth and Deutsche Umwelthilfe (DUH) to enforce air quality limits. While some officials and specialists have questioned the science linking nitrogen dioxide (NO2) to health issues, the briefing notes that the majority of researchers, the European Commission, and Germany's environment minister maintain that limits are based on sound science. The hearing aims to provide the evidence necessary to adjudicate appeals regarding diesel restrictions in 14 cities in North Rhine-Westphalia.
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Document type: Briefing
Principles of Equitable Policy Design for Energy Storage
The Union of Concerned Scientists and a coalition of stakeholders established six policy principles for energy storage to ensure the transition to clean energy benefits disadvantaged and frontline communities. These principles focus on reducing emissions, improving disaster resilience, promoting local economic development through job training, accelerating renewable energy deployment, protecting consumers from high costs, and ensuring transparent community participation in project planning.
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Document type: Fact sheet
Climate Change Toolkit for Health Professionals
The document outlines adaptation strategies for various climate-related health risks in Canada, including extreme temperature events, flooding, wildfires, food insecurity, vector-borne diseases, and water quality issues. It provides specific examples of municipal actions—such as Toronto's green roof bylaws and Vancouver's warming centres—and offers actionable tips for health professionals to support vulnerable patients and advocate for resilient community policies.
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Document type: Guide
Estimating on-road vehicle fuel economy in Africa
The paper develops a methodology to estimate fuel economy in sub-Saharan African cities, specifically Nairobi, by collecting data on both formal and informal vehicle fleets. Using general linear modelling (GLM) and artificial neural networks (ANN), the study found that fuel economy for bodabodas, tuktuks, passenger cars, and matatus in Nairobi is 2–3 times worse than in their countries of import. The GLM was identified as the more effective model for predicting fuel economy based on vehicle characteristics.
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Document type: Research paper
Air quality and health impacts of ESKOM’s planned non-compliance with South African Minimum Emission Standards
The report finds that granting Eskom's requests for non-compliance with Minimum Emission Standards would lead to significant excess emissions of SO2, NOx, particulate matter, and mercury, resulting in an estimated 16,000 avoidable premature deaths across South Africa, with 3,100 of those in the Gauteng region.
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Document type: Research paper
SUBMISSIONS ON ARCELORMITTAL VANDERBIJLPARK WORKS’ APPLICATION FOR A POSTPONEMENT AND ALTERNATIVE PLANT STANDARDS OF THE LISTED ACTIVITIES AND ASSOCIATED MINIMUM EMISSION STANDARDS
A formal submission by the Vaal Environmental Justice Alliance (VEJA) and groundWork (gW) objecting to ArcelorMittal South Africa's (AMSA) application for postponements and alternative emission standards at its Vanderbijlpark Works facility.
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Document type: Statement
SUBMISSIONS ON ARCELORMITTAL VANDERBIJLPARK WORKS’ APPLICATION FOR A POSTPONEMENT AND ALTERNATIVE PLANT STANDARDS OF THE LISTED ACTIVITIES AND ASSOCIATED MINIMUM EMISSION STANDARDS
The document argues that AMSA's requests for emission standard postponements and alternative limits for hydrogen sulfide (H2S), sulfur dioxide (SO2), and hydrochloric acid (HCl) are unlawful and should be denied. The authors contend that the Vanderbijlpark Works is located in a non-compliant air quality priority area, that AMSA has failed to provide sufficient technical or economic justification for its requests, and that the company's history of non-compliance renders it unfit to receive such concessions.
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Document type: Statement
Doha Declaration on Climate, Health and Wellbeing
The Doha Declaration on Climate, Health and Wellbeing, drafted by the Global Climate and Health Alliance in December 2012, asserts that health should be central to climate action. It highlights that climate change impacts health through direct means, such as extreme weather and infectious diseases, and indirect means, such as migration and conflict, disproportionately affecting children, women, and poorer populations. The declaration argues that climate mitigation—specifically reducing fossil fuel consumption and shifting to low-carbon energy—provides significant health co-benefits, including improved air quality and increased physical activity. The signatories call for health impacts to be fully evaluated and costed in climate decisions, the cessation of global fossil fuel subsidies, increased funding for health programs in vulnerable countries, and the inclusion of the health sector in designing mitigation and adaptation strategies.
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Document type: Statement
URGENT FOLLOW UP ON REQUEST FOR URGENT WITHDRAWAL OF THE PROVISION IN THE LIST OF ACTIVITIES REGARDING THE WEAKENING OF THE SULPHUR DIOXIDE NEW PLANT MINIMUM EMISSION STANDARDS FOR EXISTING PLANTS
The Centre for Environmental Rights, representing several environmental groups, is demanding the withdrawal of an amendment to the List of Activities that weakened sulphur dioxide minimum emission standards for existing plants. The groups argue the amendment was made without following legally-prescribed public participation procedures and threaten High Court litigation if the provision is not withdrawn by 12 March 2019.
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Document type: Statement