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Soot to Solar
The Waukegan Generating Station in Illinois causes significant health harms, including an estimated 18 premature deaths annually, and disproportionately affects people of color. Analysis indicates that the plant's coal units can be retired without impacting electricity reliability, as generation can be replaced across the PJM regional transmission organization. The document proposes a just transition involving site remediation, energy storage, and the use of nearby brownfield sites for solar projects under the Future Energy Jobs Act (FEJA).
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Document type: Fact sheet
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
THE DEVELOPMENT BANK OF SOUTHERN AFRICA’S ROLE IN FINANCING PROPOSED NEW COAL-FIRED POWER PLANTS
The Centre for Environmental Rights is challenging the Development Bank of Southern Africa's (DBSA) refusal to provide details and legal reasons for its decision-making process regarding the financing of the Thabametsi and Khanyisa coal-fired power plants. The Centre argues that as an organ of state, the DBSA's funding decisions constitute administrative action under the Promotion of Administrative Justice Act, 2000 (PAJA), and that the bank's mandate to promote sustainable development necessitates transparency.
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Document type: Statement
ABSA GROUP LIMITED’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, calls on ABSA Group Limited to cease financing the Thabametsi and Khanyisa coal-fired power stations. The CER argues that these projects are not 'procured' due to missing or challenged legal authorisations, including atmospheric emission and water use licences. 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 highlights that the plants would be located in polluted air quality priority areas, causing severe health impacts and producing greenhouse gas emissions nearly 60% higher than the Medupi and Kusile stations. Financially, the CER claims the inclusion of new coal in the draft IRP would cost South Africa nearly R20 billion more than necessary, increasing costs for consumers.
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Document type: Statement
FIRSTRAND BANK’S ROLE IN FINANCING THE PROPOSED THABAMETSI COAL-FIRED POWER PLANT
The Centre for Environmental Rights (CER), representing the Life After Coal Campaign, argues that financing the Thabametsi and Khanyisa coal-fired power plants is unjustifiable. The document asserts that these projects are not 'least-cost' options, face significant legal challenges regarding environmental and water licenses, and would cause severe health and climate damage. It specifically calls on FirstRand Bank to cease support for Thabametsi to avoid reputational risk and align with its own commitments to a lower-carbon economy.
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Document type: Statement
NEDBANKS ROLE IN FINANCING PROPOSED NEW COAL-FIRED POWER PLANTS
The Centre for Environmental Rights (CER), writing on behalf of the Life After Coal Campaign, calls on Nedbank to cease financing the Thabametsi and Khanyisa coal-fired power stations. The CER argues that these projects, part of the Coal Baseload Independent Power Producer Procurement Programme (CBIPPPP), are not 'procured' as claimed in the draft Integrated Resource Plan (IRP) 2018 because they lack essential legal authorisations, including atmospheric emission and water use licences. The document asserts that these plants are unnecessary for electricity supply, excessively expensive, and would cost South Africa nearly R20 billion more than required. Furthermore, it highlights severe health risks for residents in the Waterberg-Bojanala and Highveld Priority Areas and warns that the plants' high greenhouse gas emission intensities would undermine South Africa's Paris Agreement commitments. The CER criticizes Nedbank for excluding these 'existing commitments' from its 2018 policy against financing new coal-fired power plants.
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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
SUBMISSIONS ON THE BACKGROUND INFORMATION DOCUMENT (BID) FOR ESKOMassung FOR POSTPONEMENT OF THE MINIMUM EMISSION STANDARDS (MES) FOR 14 OF ITS COAL AND LIQUID FUEL-FIRED POWER STATIONS
The Life After Coal campaign, representing several environmental and community alliances, strongly objects to Eskom's request to postpone Minimum Emission Standards (MES) for 14 coal and liquid fuel-fired power stations. The submission argues that under the National Environmental Management: Air Quality Act (AQA) and the associated Framework, postponements are only permissible if ambient air quality standards in the area are in compliance, which is not the case for the Highveld Priority Area (HPA), Vaal Triangle Airshed Priority Area (VTAPA), and Waterberg-Bojanala Priority Area (WBPA). The document highlights severe health impacts, including thousands of premature deaths attributed to PM2.5 emissions, and criticizes Eskom's Background Information Document (BID) for being inaccurate and incomplete. The campaign demands the rejection of the applications, the cessation of 'rolling postponements', and a just transition toward renewable energy.
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Document type: Statement
New US Tax Incentives for CCUS (The FUTURE Act)
The FUTURE Act provides tax credits for CO2 captured from power plants, industrial sources, and direct air capture, with rates ramping up to $50/ton for saline storage and $35/ton for enhanced oil recovery by 2026. The credits are available for 12 years to projects that commence construction within a six-year window. Assessments by the IEA and DOE suggest the act could increase capture capacity or reduce emissions by 10 to 30 million tons by 2030, with significant interest from industrial sources and companies like Occidental Petroleum.
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Document type: Briefing
CATF Statement on Proposed Repeal of Clean Power Plan
The Clean Air Task Force opposes the EPA's proposed replacement of the Clean Power Plan, arguing it violates the Clean Air Act and would lead to approximately 1,000 avoidable deaths per year by extending the operation of old coal plants.
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Document type: Statement
THE DEVELOPMENT BANK OF SOUTHERN AFRICA’S ROLE IN FINANCING PROPOSED NEW COAL-FIRED POWER PLANTS
The CER argues that the DBSA's potential financing of the Thabametsi and Khanyisa coal-fired power plants contradicts its mandate for sustainable development and violates constitutional environmental rights. The CER highlights that these projects face significant legal challenges regarding licenses and would result in greenhouse gas emission intensities nearly 60% higher than Eskom's Medupi and Kusile plants. Furthermore, the CER cites evidence that South Africa has surplus base supply capacity and that these plants would increase costs by R19.68 billion compared to a least-cost energy system.
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Document type: Statement
PremierFord_ClimateLetter
A coalition of over 115 organizations, including the Canadian Association of Physicians for the Environment, calls on Ontario Premier Doug Ford to reinstate climate policy and meet legislated emissions targets. The letter highlights the increasing financial and human costs of climate change in Ontario, citing record heat waves, floods, and forest fires, and notes that Ontario is Canada's second most carbon-polluting province.
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Document type: Statement
COAL BASELOAD INDEPENDENT POWER PRODUCERS – STATUS OF THE POWER PURCHASE AGREEMENTS
The Centre for Environmental Rights (CER), on behalf of the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, has written to Eskom to challenge the procurement of two coal-fired independent power producers (IPPs): Thabametsi and Khanyisa. The CER argues that these projects are not 'value for money' as they would increase system costs by 19.6 billion Rand, raise greenhouse gas emissions, and risk becoming stranded assets. The letter highlights that the projects lack necessary licenses and are subject to pending High Court reviews. It requests detailed information on the status of the PPAs, the 'value for money' assessment, and compliance with the Public Finance Management Act (PFMA) and New Generation Regulations.
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Document type: Statement
COAL BASELOAD INDEPENDENT POWER PRODUCERS – STATUS OF THE POWER PURCHASE AGREEMENTS
The Centre for Environmental Rights (CER), representing the Life After Coal Campaign, is challenging the progression of the Thabametsi and Khanyisa coal-fired power stations. The CER argues that these projects fail the 'value for money' test, would increase greenhouse gas emissions, and are unable to reach commercial close due to missing licenses and pending High Court reviews. The letter requests detailed information on the status of the procurement process and the specific regulatory approvals required before PPAs can be signed.
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Document type: Statement
REDIRECTING FEDERAL FUNDS TOWARD COAL AND NUCLEAR PLANT COMMUNITIES
The research note analyzes a U.S. Department of Energy proposal to subsidize uneconomic power plants to maintain grid reliability. It estimates that keeping six FirstEnergy coal and nuclear plants online for two years would cost approximately $2 billion. The author contends that these funds would be better spent on locally-led economic diversification and workforce development, noting that grid operators and reliability bodies do not believe such interventions are necessary for stability. The document suggests that redirecting these funds could provide over $300 million per affected community to support a just transition.
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Document type: Research paper
Just Transition for Workers and Communities Displaced by Climate Action
The Canadian Association of Physicians for the Environment (CAPE) advocates for the rapid closure of coal plants in Canada to reduce greenhouse gas emissions and mitigate severe health risks from air pollution and mercury. While supporting this transition, CAPE stresses that unemployment and poverty are social determinants of health, requiring a just transition framework including retraining, relocation programs, and extended severance to prevent the health benefits of decarbonization from being offset by economic instability for workers.
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Document type: Statement
Water Impacts and Externalities of Coal Power
The report examines the negative externalities of coal power in South Africa, focusing on water consumption, pollution, and health impacts. It argues that the current energy planning (Draft IRP) underestimates the true cost of coal by ignoring water-related externalities, such as acid-mine drainage and the high cost of water treatment. The document suggests that internalising these costs would justify a rapid transition to water-efficient renewable energy, which would also create more jobs and reduce the disproportionate burden on marginalised communities.
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Document type: Report
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, on behalf of the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, supports the elimination of 'rolling postponements' for emission standards but argues that the draft legislation lacks sufficient safeguards. The submission recommends that postponement applications be contingent on ambient air quality compliance, require full public disclosure of decommissioning schedules, and mandate stricter emission standards for facilities seeking once-off suspensions, particularly in air quality priority areas.
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Document type: Statement
RELEVANT INFORMATION CONCERNING THE COAL IPPS – A STUDY BY THE ENERGY RESEARCH CENTRE
The Life After Coal Campaign informs the South African Minister of Finance that a study by the University of Cape Town's Energy Research Centre (ERC) finds the Thabametsi and Khanyisa coal-fired power stations are unnecessary and economically harmful. The campaign argues these projects would increase system costs by R19.68 billion, raise greenhouse gas emissions by 205.7Mt CO2eq over 30 years, and exacerbate Eskom's financial crisis. The letter advocates for a transition to renewable energy to ensure financial stability and meet Paris Agreement commitments.
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Document type: Statement
SUBMISSIONS ON THE OPERATIONALISATION OF THE POST 2020 MITIGATION SYSTEM
The Centre for Environmental Rights (CER) submitted comments to the South African Department of Environmental Affairs (DEA) on the post-2020 mitigation system. The CER advocates for the use of the 'low peak plateau decline (PPD) trajectory' for mitigation ambition and strongly opposes the use of 'grandfathering' (historical emissions) to set carbon budgets, as it rewards polluters. The document emphasizes the necessity of public access to facility-level greenhouse gas (GHG) emission data, citing precedents in the EU, USA, and Australia, and objects to the DEA's use of Non-Disclosure Agreements to keep such data confidential. Regarding the carbon tax, the CER argues it should remain a distinct instrument from carbon budgets and should apply to all emissions rather than only those exceeding budgets. Additionally, the CER highlights an Energy Research Centre (ERC) report finding that proposed coal-fired power stations (Thabametsi and Khanyisa) are not least-cost, are unnecessary for demand, and would increase GHG emissions by 205.7Mt CO2eq over 30 years.
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Document type: Statement