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Comments on the Draft Declaration of Greenhouse Gases as Priority Pollutants & the National Pollution Prevention Plans Regulations
The Centre for Environmental Rights (CER), representing several environmental justice organisations, submitted comments on 8 February 2016 regarding the Draft Declaration of Greenhouse Gases as Priority Pollutants and the Draft National Pollution Prevention Plans (PPP) Regulations. The submission argues for greater alignment between these regulations and South Africa's international commitments under the Paris Agreement and its Intended Nationally Determined Contribution (INDC), while advocating for increased transparency, public access to data, and more rigorous monitoring and verification of greenhouse gas (GHG) emissions.
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Document type: Statement
ENVIRONMENTAL JUSTICE STATE GUIDANCE FOR CLEAN POWER PLANNING
The document outlines strategies for US states to ensure that the Clean Power Plan does not disproportionately burden low-income communities and communities of color. It emphasizes the need for 'high impact' engagement, the conduct of formal Environmental Justice (EJ) analyses, and the avoidance of carbon trading mechanisms that may allow power plants to avoid on-site pollution reductions. The guide also advocates for a 'Just Transition' that provides economic development and job training in communities heavily dependent on fossil fuels.
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Document type: Guide
CLIMATE CHANGE IN THE BASQUE COUNTRY: IMPACT ON HEALTH AND ADAPTATION MEASURES
The document outlines expected climate impacts in the Basque Country, including rising temperatures, sea-level rise, and altered precipitation, which threaten public health through heat waves, flooding, and increased pollutants. It identifies 26 adaptation measures, highlighting the cost-effectiveness and co-benefits of ecosystem-based solutions like Sustainable Urban Drainage Systems (SUDS) and behavioral changes in transport.
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Document type: Policy brief
National Environmental Compliance and Enforcement Report 2015/16
The National Environmental Compliance and Enforcement Report 2015/16 details the activities of South Africa's Environmental Management Inspectorate (EMI). It records a total of 2,647 EMIs, with a significant increase in proactive inspections and a rise in administrative notices. The report highlights enforcement trends in 'brown' (pollution/waste), 'green' (biodiversity), and 'blue' (marine/freshwater) sectors, noting a stabilization in rhino poaching numbers. It also documents specific legal cases, legislative updates, and capacity-building efforts for inspectors and prosecutors.
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Document type: Report
The journey to clean cooking: Practical insights from case studies in Kenya and Zambia
The document argues that while affordability and aspirational appeal drive the initial purchase of advanced cookstoves, long-term adoption depends on the stove's performance and the availability of ongoing user support. Based on case studies in Kenya and Zambia, it highlights that shifting cooking habits is a complex behaviour change process requiring hands-on trials, clear manuals, and personal follow-up to prevent users from abandoning new technology in frustration.
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Document type: Briefing
CER COMMENTS ON THE UPDATED MULTI-STAKEHOLDER REFERENCE GROUP TERMS OF REFERENCE FOR THE IMPLEMENTATION OF THE HIGHVELD PRIORITY AREA AIR QUALITY MANAGEMENT PLAN
The Centre for Environmental Rights (CER), acting on behalf of several community and environmental organisations, submitted comments on 11 December 2015 regarding the updated Terms of Reference (ToR) for the implementation of the Highveld Priority Area (HPA) Air Quality Management Plan (AQMP). The CER argues that the ToR must be expanded to ensure broader government participation, mandatory attendance from industry and municipal leaders, and improved transparency and accessibility of air quality data and meeting documentation.
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Document type: Statement
COMMENTS ON THE DRAFT REGULATIONS FOR THE PROCEDURE AND CRITERIA TO BE FOLLOWED IN THE DETERMINATION OF AN ADMINISTRATIVE FINE IN TERMS OF SECTION 22A OF THE NATIONAL: ENVIRONMENTAL MANAGEMENT: AIR QUALITY ACT
The Centre for Environmental Rights (CER) submitted comments on November 9, 2015, regarding draft regulations for determining administrative fines under section 22A of the National: Environmental Management: Air Quality Act (AQA). The CER argues that the draft regulations lack consistency with other environmental fine mechanisms and fail to provide for public participation, proposing specific amendments to the fine calculation and the inclusion of aggravating factors.
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Document type: Statement
Closure of Alberta's Coal Plants: A Boon for Canada's Climate, Alberta's Air, Health
The document advocates for the closure of Alberta's coal-fired power plants to meet national climate goals and reduce severe health impacts. It highlights that Alberta is Canada's most carbon-intensive province and that coal plants contribute significantly to air pollutants linked to premature deaths and hospitalizations. Using the Ontario coal phase-out as a successful precedent, the brief argues that similar action in Alberta would lower greenhouse gas emissions and reduce the economic and human cost of air pollution.
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Document type: Policy brief
THE CLEAN AIR HANDBOOK
The handbook explains the legal framework of the EU Air Quality Directive, emphasizing the enforceability of 'limit values' for pollutants like NO2 and PM10. It details how citizens and NGOs can use the Aarhus Convention's pillars—access to information, public participation, and access to justice—to challenge inadequate air quality plans and government inaction in national courts. The document also outlines the European Commission's infringement procedures and the 'Fresh Approach' to tackling systemic breaches of air quality standards across Member States.
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Document type: Guide
ENVIRONMENTAL, HEALTH AND SAFETY IMPACTS OF THE PROPOSED OAKLAND BULK AND OVERSIZED TERMINAL
The report argues that the proposed Oakland Bulk and Oversized Terminal (OBOT) poses significant risks to public health, water security, and local ecosystems, particularly if used to export coal. The author highlights that current design plans are conceptual and lack enforceable controls for dust and emissions. Key concerns include the consumption of 79.2 million gallons of water annually for dust control during a record drought, the release of up to 18,300 tons of coal dust per year within California from uncovered rail cars, and increased cancer risks from diesel particulate matter in West Oakland. Additionally, the report notes that the project's scale would cause significant traffic congestion at 55 at-grade rail crossings and create substantial noise pollution. The author concludes that these impacts were not addressed in the project's CEQA review.
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Document type: Report
A Good First Step – But We Have a Long Way to go on Oil and Gas
The Clean Air Task Force acknowledges the USEPA's 2015 proposal to reduce methane emissions from the oil and gas industry as a significant first step, noting it introduces the first greenhouse gas standards for the sector. However, the authors argue that the proposed rules only reduce 2012 emissions by approximately 7.5% and will not be sufficient to meet the White House goal of a 40-45% reduction by 2025. They emphasize that because existing sites are predicted to represent 90% of the sector's total methane emissions in 2018, the EPA must issue emissions guidelines for existing sources under the Clean Air Act to achieve the necessary reductions.
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Document type: Statement
SUBMISSIONS ON DEPARTMENT OF ENVIRONMENTAL AFFAIRS’ DRAFT AIR QUALITY OFFSETS GUIDELINE DATED JANUARY 2015
The Centre for Environmental Rights (CER), representing several environmental justice alliances, submitted a formal objection to the Department of Environmental Affairs' draft Air Quality Offsets Guideline (January 2015). The CER argues that the proposed offsets are actually forms of compensation that lack a legislative framework and could be used by polluters to avoid legal compliance with emission standards.
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Document type: Statement
Health impacts of atmospheric pollution in a changing climate
The paper examines the severe health and economic burdens of air pollution, noting that global premature deaths could double by 2050. It details the Impact Pathway Approach (IPA) for monetizing health damages and analyzes European industrial emissions data, identifying the power generating sector as the largest contributor to damage costs. The authors propose enhancing these assessments by integrating satellite-based Earth observation data from the MACC/Copernicus services to reduce model errors and provide higher resolution global and regional air quality analysis.
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Document type: Research paper
The End of Coal: Ontario’s coal phase-out
Ontario eliminated coal-fired electricity generation by the end of 2014, a process described as the "single largest GHG reduction measure in North America." The transition was primarily driven by public health concerns and the influence of a coalition including the Ontario Medical Association and the Ontario Clean Air Alliance. Key enabling factors included the public ownership of coal plants, which allowed the government to absorb shutdown costs, and the lack of local coal reserves, which minimized economic resistance from producers. While the phase-out significantly reduced greenhouse gas emissions by approximately 34 megatonnes since 2007, the report notes that coal was largely replaced by natural gas rather than renewables. The experience highlights the importance of credible messengers, realistic timelines, and multi-party political consensus in achieving large-scale energy transitions.
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Document type: Report
APPEAL IN TERMS OF SECTION 62 OF THE LOCAL GOVERNMENT: MUNICIPAL SYSTEMS ACT, 2000 OF ESKOM’S LETHABO POWER STATION ATMOSPHERIC EMISSION LICENCE FDDM-MET-2011-08-P1 ISSUED ON 1 APRIL 2015
The Centre for Environmental Rights (CER), representing groundWork, Earthlife Africa Johannesburg, and the Vaal Environmental Justice Alliance, filed an appeal on May 28, 2015, against the atmospheric emission licence (AEL) FDDM-MET-2011-08-P1 issued to Eskom's Lethabo Power Station. The appeal argues that the Fezile Dabi District Municipality failed to consider critical health impacts and ambient air quality standards when varying the AEL to incorporate the National Air Quality Officer's (NAQO) decisions to postpone compliance with Minimum Emission Standards (MES).
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Document type: Statement
Five Actions EPA Should Take When Issuing Much-Needed Methane Pollution Standards
The Clean Air Task Force reports that over 60 organizations have urged the EPA to implement comprehensive methane standards for new and modified oil and gas equipment. The requests include mandatory leak detection and repair across the entire sector, extending green completions to oil wells with significant gas production, reducing emissions from liquids unloading and pneumatic equipment, and covering the full supply chain including transmission and storage.
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Document type: Statement
APPEAL IN TERMS OF SECTION 62 OF ESKOM’S CAMDEN POWER STATION ATMOSPHERIC EMISSION LICENCE MSUKALIGWA/ESKOM H SOC LTD/CPS/0012/2015/F02 ISSUED ON 31 MARCH 2015
The Centre for Environmental Rights (CER), representing groundWork, Earthlife Africa Johannesburg, and the Highveld Environmental Justice Network, filed an appeal on May 20, 2015, against the atmospheric emission licence (AEL) issued to Eskom's Camden Power Station. The appeal argues that the Gert Sibande District Municipality failed to consider the severe health impacts and poor air quality of the Highveld Priority Area (HPA) when granting emission limit postponements that allow pollutants to exceed national minimum emission standards (MES).
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Document type: Statement
APPEAL IN TERMS OF SECTION 62 OF THE LOCAL GOVERNMENT: MUNICIPAL SYSTEMS ACT, 2000 OF ESKOM’S HENDRINA POWER STATION ATMOSPHERIC EMISSION LICENCE 17/4/AEL/MP312/11/16 ISSUED ON 31 MARCH 2015
This document is a formal appeal submitted by the Centre for Environmental Rights (CER) on behalf of groundWork, Earthlife Africa Johannesburg, and the Highveld Environmental Justice Network. The appeal challenges the variation of the Atmospheric Emission Licence (AEL) for Eskom's Hendrina Power Station, issued by the Nkangala District Municipality on 31 March 2015. The appellants argue that the AEL improperly incorporates postponements of Minimum Emission Standards (MES) granted by the National Air Quality Officer, thereby permitting pollution levels that exceed national standards in a declared priority area with already compromised air quality.
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Document type: Report
APPEAL PURSUANT TO SECTION 43(2) OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 AGAINST ENVIRONMENTAL AUTHORISATION GRANTED TO NEWSHELF 1282 (PTY) LIMITED ON 25 FEBRUARY 2015
This document is an appeal submitted by Earthlife Africa Johannesburg on 11 May 2015 to the Minister of Environmental Affairs. The appeal challenges the environmental authorisation granted on 25 February 2015 to Newshelf 1282 (Pty) Limited for the construction of the 1200 megawatt (MW) coal-fired Thabametsi power station near Lephalale in the Limpopo Province. The appellant argues that the decision was unlawful, failed to consider critical air quality and water scarcity issues, ignored climate change obligations, and violated the Promotion of Administrative Justice Act (PAJA).
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Document type: Statement
APPEAL IN TERMS OF SECTION 62 OF OF THE LOCAL GOVERNMENT: MUNICIPAL SYSTEMS ACT, 2000 OF ESKOM’S KOMATI POWER STATION ATMOSPHERIC EMISSION LICENCE 17/4/AEL/MP313/12/12 ORIGINALLY ISSUED ON 31 MARCH 2015
The Centre for Environmental Rights, representing environmental justice organisations, appealed the Atmospheric Emission Licence (AEL) for Eskom's Komati Power Station. The appeal argues that the AEL illegally allows Eskom to exceed national Minimum Emission Standards (MES) for NOx and SO2, ignoring the critical air quality failure in the Highveld Priority Area and the resulting health impacts on the population.
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Document type: Statement