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eesi_e15_letter_of_support-f84128bab818690f.pdf
EESI advocates for the sale of E15 (15 percent ethanol, 85 percent gasoline) in New York State, arguing that it improves air quality and reduces greenhouse gas emissions compared to E10. The document highlights that E15 reduces volatile organic compound (VOC) emissions and displaces toxic "gasoline aromatics" like the BTEX complex, which are linked to cancer. It also notes that E15 does not increase tailpipe emissions or damage catalysts in older vehicles and contributes to a reduction in transportation-sector greenhouse gases, with corn ethanol being on average 43 percent less GHG intensive than gasoline.
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Document type: Statement
Cities as the new environmental watchdog in the EU
The CJEU ruled on 13 December (2018) that cities such as Brussels, Paris, and Madrid have standing under Article 263 TFEU to challenge EU regulations if those regulations prevent them from exercising their regulatory powers. In this case, the cities successfully challenged the 'conformity factor' in Commission Regulation 2016/646, which had relaxed the Euro 6 emissions standard. The court found that the regulation restricted the cities' ability to ban vehicles that met the relaxed standard but exceeded stricter emission limits. This decision is framed as a landmark for access to justice, potentially allowing cities to act as environmental watchdogs and challenge other EU measures, such as the authorization of glyphosate.
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Document type: Legal commentary
Mpumalanga Spatial Development Framework
The Mpumalanga Provincial Spatial Development Framework proposes a polycentric growth management model to address apartheid-era spatial imbalances and promote sustainable economic diversification. It identifies five key economic growth and innovation centres—Mbombela, Emalahleni, Middleburg, Secunda, and Ermelo—and a network of alternative growth centres to decentralise economic activity. The framework emphasises enhancing connectivity via the N4 Maputo Corridor and other strategic routes, protecting high-potential agricultural land and biodiversity, and transitioning the province's coal-dependent economy toward low-carbon and climate-resilient alternatives. It also outlines strategies for urban densification, the development of sustainable human settlements, and the creation of Rural Economic Zones (REZ) to transform rural livelihoods.
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Document type: Report
THE EVOLUTION OF BIKE SHARING: 10 QUESTIONS ON THE EMERGENCE OF NEW TECHNOLOGIES, OPPORTUNITIES, AND RISKS
The document analyzes the evolution of bicycle-sharing schemes (BSS) across four technological generations, moving from simple free-bike models to sophisticated dockless and electric systems. It provides a comprehensive guide for city officials on planning, regulatory frameworks, financing, and safety, emphasizing the need for proactive governance to manage the risks and opportunities of the 'fourth generation' of bike sharing.
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Document type: Research paper
Reducing Emissions from Transportation in the Northeast and Mid-Atlantic
The document argues that Northeast and Mid-Atlantic states can significantly reduce CO2 pollution and consumer fuel spending by transitioning to electric vehicles and low-carbon fuels. It highlights specific targets for emissions cuts and emphasizes the need for equitable investments that prioritize polluted communities and marginalized populations.
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Document type: Fact sheet
Spatial Challenges and Opportunities Report
The report analyzes Mpumalanga's spatial status, identifying a resource-rich province dominated by coal mining and agriculture but facing severe environmental degradation and infrastructure backlogs. Key findings highlight that while the province is a national energy hub, it suffers from poor air quality in the Highveld, critical water scarcity, and significant housing shortages. The analysis emphasizes the need for urban restructuring, agrarian transformation in rural areas, and the protection of strategic water source areas and biodiversity corridors against mining encroachment.
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Document type: Report
Soot to Solar
The report argues that accelerating the retirement of coal plants in Illinois in favor of clean energy technologies will improve public health, reduce carbon emissions, and lower electricity bills without compromising grid reliability.
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Document type: Executive summary
COMMENTS ON THE REVISED ATMOSPHERIC IMPACT REPORT AND ATMOSPHERIC EMISSION LICENCE APPLICATION FOR THE PROPOSED IPP THABAMETSI COAL-FIRED POWER STATION
The Centre for Environmental Rights (CER), on behalf of Earthlife Africa and groundWork, submitted comments on September 20, 2018, objecting to the Atmospheric Emission Licence (AEL) application for the proposed Thabametsi coal-fired power station. The CER argues that the project should be refused because it is located in an air quality priority area already in non-compliance with National Ambient Air Quality Standards (NAAQS) and is predicted to cause further non-compliance, specifically regarding sulphur dioxide (SO2). The CER claims the Atmospheric Impact Report (AIR) is fatally flawed due to gross miscalculations of emissions, missing modelling data, and a failure to adequately assess cumulative and health impacts.
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Document type: Statement
STANDARD BANK’S ROLE IN FINANCING PROPOSED NEW COAL-FIRED POWER PLANTS
The Centre for Environmental Rights (CER), writing on behalf of the Life After Coal Campaign, has called on Standard Bank to cease financing the Thabametsi and Khanyisa coal-fired power stations. The CER argues that these projects are not 'procured' due to missing atmospheric emission, water use, and generation licences, and are subject to High Court reviews. The document asserts that the 2018 draft Integrated Resource Plan (IRP) incorrectly includes these projects despite a 'least cost' option consisting only of solar, wind, and gas. The CER claims the projects would cost South Africa nearly R20 billion more than necessary, increase electricity prices for consumers, and exacerbate severe health issues in the Waterberg-Bojanala and Highveld Priority Areas. Furthermore, the CER highlights that these plants would have greenhouse gas emission intensities 'almost 60% higher than Eskom’s Medupi and Kusile power stations', undermining South Africa's Paris Agreement commitments.
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Document type: Statement
mayors-california-carb-letter-supporting-zebs-eb258d8d28714e2f.pdf
Mayors from across California are calling on the California Air Resources Board to move beyond incentives and implement regulatory measures to transition transit fleets to zero-emission buses. They argue that these vehicles are technologically viable, cost-competitive, and essential for reducing toxic air pollution and meeting the state's 2030 greenhouse gas reduction goals.
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Document type: Statement
Building a Healthier Democracy
The report analyzes how electoral rules—including registration eligibility, voting processes, and districting—impact voter turnout, particularly in environmental justice communities. It finds that socioeconomic distress and poor air quality are significant depressors of turnout, and that states with biased districting plans tend to have higher levels of air toxin exposure. The authors argue that restrictive election laws insulate powerful interests and weaken environmental protections, citing the Flint water crisis as an example of legislative dysfunction resulting from gerrymandering. The document recommends reforms such as automatic voter registration, nonpartisan redistricting, and proportional representation to improve government responsiveness and public health outcomes.
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Document type: Report
Turning Down the Gas in California
The analysis finds that no new natural gas capacity is needed to maintain grid reliability in California through 2030. Depending on carbon caps and the use of battery storage to meet local capacity requirements (LCR), between 28 and 56 of the 89 modeled natural gas plants could be retired. While overall natural gas generation decreases, the report warns that remaining plants may cycle on and off more frequently, potentially increasing NOx emissions and harming air quality in nearby disadvantaged communities.
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Document type: Report
PROVISIONAL SUBMISSIONS REGARDING THE REVIEW OF THE 2012 NATIONAL FRAMEWORK FOR AIR QUALITY MANAGEMENT IN THE REPUBLIC OF SOUTH AFRICA
The Centre for Environmental Rights (CER), representing several environmental justice organisations, submitted provisional comments on June 29, 2018, regarding the Department of Environmental Affairs' (DEA) proposed amendments to the 2012 National Framework for Air Quality Management in South Africa. The CER argues that the public consultation process was inadequate and that the draft Framework fails to address systemic failures in air quality monitoring, enforcement, and the achievement of previous targets.
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Document type: Statement
REPRESENTATIONS ON THE NOTICE OF INTENTION TO AMEND THE LIST OF ACTIVITIES WHICH RESULT IN ATMOSPHERIC EMISISONS WHICH HAVE OR MAY HAVE A SIGNFICANT DETRIMENTAL EFFECT ON THE ENVIRONMENT, INCLUDING HEALTH, SOCIAL CONDITIONS, ECONOMIC CONDITIONS, ECOLOGICAL CONDITIONS OR CULTURAL HERITAGE
The Centre for Environmental Rights, representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted representations on June 25, 2018, regarding proposed amendments to the List of Activities resulting in atmospheric emissions. While supporting the elimination of 'rolling postponements' for minimum emission standards (MES), the submission argues for stricter requirements for once-off suspensions, greater transparency in application documents, and a more robust public participation process.
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Document type: Statement
RMI and Uber Team Up to Expand Shared and Electric Mobility
RMI and Uber collaborated on an EV Pilot in Austin, Texas, to transition high-mileage rideshare drivers to electric vehicles. Through driver focus groups and education sessions, the project identified key barriers to adoption—including insufficient DC fast charging, range anxiety, and lack of awareness regarding cost savings—and developed strategies to address them, such as in-app notifications for riders and strategic charging infrastructure deployment by Austin Energy.
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Document type: Case study
NOTICE IN TERMS OF SECTION 28(12) OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998, IN RELATION TO ARCELORMITTAL SOUTH AFRICA’ S OPERATIONS AT VANDERBIJLPARK
The Centre for Environmental Rights (CER), representing the Vaal Environmental Justice Alliance (VEJA), groundWork, and affected community members, issued a formal notice to the Director-General of the Department of Environmental Affairs (DEA) on 18 June 2018. The notice, submitted under section 28(12) of the National Environmental Management Act, 1998 (NEMA), demands that the DEA take enforcement action against ArcelorMittal South Africa (AMSA) for significant and ongoing pollution of air, soil, and water at its Vanderbijlpark operations.
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Document type: Statement
COMMENTS ON THE FINAL ENVIRONMENTAL IMPACT REPORT AND WASTE MANAGEMENT LICENCE VARIATION APPLICATION FOR THE PROPOSED RETROFITTING OF A FLUE GAS DESULPHURISATION SYSTEM AT MEDUPI POWER STATION, LEPHALALE, LIMPOPO PROVINCE
The Centre for Environmental Rights (CER), acting for groundwork, Earthlife Africa, and Concerned Citizens of Lephalale, submitted comments on 15 June 2018 objecting to the Final Environmental Impact Report (FEIR) and Waste Management Licence (WML) Variation Application for the Flue Gas Desulphurisation (FGD) Retrofit Project at Medupi Power Station. The CER argues that the FEIR is deficient due to missing data, a 'piecemeal' approach to environmental authorisations, and a failure to adequately assess water and waste impacts.
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Document type: Statement
Comments on AER DRAFT Directive 060: Upstream Petroleum Industry Flaring, Incinerating, and Venting and Directive 017: Measurement Requirements for Oil and Gas Operations
The Canadian Association of Physicians for the Environment (CAPE) submitted comments on May 27, 2018, regarding the Alberta Energy Regulator's (AER) Draft Directive 060 and Directive 017. CAPE argues that Alberta's proposed methane regulations are generally less stringent and less enforceable than federal regulations, potentially leading to higher emissions and associated public health risks from co-pollutants.
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Document type: Statement
RELEVANT INFORMATION ON THE COAL INDEPENDENT POWER PRODUCERS (IPPS)
The Centre for Environmental Rights (CER) argues that the Thabametsi and Khanyisa coal-fired power stations are unnecessary, economically damaging, and environmentally harmful. CER highlights that Thabametsi's climate impact assessment rated its GHG emissions as "Very Large" and that both plants would be located in air quality priority areas. The document asserts that these projects contradict South Africa's international climate commitments and that renewable energy offers a cheaper, cleaner alternative.
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Document type: Statement
Report of the meeting on SCIENCE-POLICY DIALOGUE FOR THE ESTABLISHMENT OF A RESEARCH PARTNERSHIP ON DECARBONIZATION AND CLIMATE RESILIENT GOVERNANCE IN MEGACITIES OF THE SOUTH
The meeting, held on 2-3 April 2018, brought together policy makers, scientists, and international organizations to establish a co-designed research program for megacities in the South. The initiative aims to provide scientific guidance for adaptation and mitigation actions, specifically targeting decarbonization in transport, housing, and waste management, as well as addressing climate-related health risks and extreme weather events. The participants outlined a seven-component research plan emphasizing governance, social dimensions of adaptation, and capacity building to support the implementation of the Paris Agreement and Sustainable Development Goals in Buenos Aires, Santiago, and Sao Paulo.
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Document type: Report