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This document is a submission from Sasol to the South African Department of Environmental Affairs (DEA) detailing the company's objections to the requirement that existing industrial plants meet 'new plant standards' for emissions by April 1, 2020. Sasol argues that retrofitting old facilities is often technically impossible due to space and configuration constraints, economically unviable, and potentially counterproductive to other environmental goals, such as carbon footprint reduction and water conservation.

This briefing document outlines technical and regulatory issues arising from a May 15, 2013, workshop between the Department of Environmental Affairs (DEA) and industry stakeholders regarding the Section 21 emission standards. It focuses on refining activity descriptions, adjusting emission limits for specific industrial processes, and addressing the legal and practical implications of including 'use of' and 'storage' in the listed activities.