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This submission by the Centre for Environmental Rights (CER), on behalf of groundWork and Earthlife Africa, opposes Eskom's applications for the postponement and suspension of Minimum Emission Standards (MES) compliance. The document argues that Eskom's failure to comply with air quality laws violates constitutional rights to health and a safe environment, particularly in the Highveld Priority Area. It provides evidence of extensive emission exceedances, high emission intensity compared to international standards, and severe public health impacts, while asserting that abatement technologies are technically and economically feasible.

The Centre for Environmental Rights (CER), representing groundWork, Earthlife Africa, and the Vaal Environmental Justice Alliance (VEJA), issued a statement to the National Environmental Consultative and Advisory (NECA) Forum regarding the consultative process established under section 3A of the National Environmental Management Act (NEMA). The CER outlines legal requirements for compliance with Minimum Emission Standards (MES) and sets minimum conditions for the Forum's operations to ensure transparency and the protection of affected communities' rights.

This government notice and accompanying Terms of Reference establish the National Environmental Consultative and Advisory Forum to advise the Minister of Forestry, Fisheries and the Environment on applications for the suspension and postponement of compliance with Minimum Emission Standards (MES) and the issuance of Provisional Atmospheric Emission Licences (PAEL).

The Centre for Environmental Rights, acting on behalf of groundWork and Earthlife Africa, submitted an appeal to the Minister of Forestry, Fisheries and the Environment on 9 February 2022. The appeal seeks to set aside decisions made by the National Air Quality Officer on 30 October 2021 regarding Eskom's applications for alternative limits and the postponement and suspension of compliance timeframes under the National Environmental Management: Air Quality Act 39 of 2004 Minimum Emission Standards.

This document is an appeal filed by groundWork and Earthlife Africa against decisions made by the National Air Quality Officer (NAQO) on 30 October 2021. The appeal disputes the granting of compliance postponements and suspensions regarding Minimum Emission Standards (MES) for several Eskom coal-fired power stations, arguing that these decisions violate the National Environmental Management: Air Quality Act (AQA), the 2017 National Framework for Air Quality Management, and the Constitution of South Africa.

This document is an appeal response report filed by groundWork and Earthlife Africa, represented by the Centre for Environmental Rights, challenging decisions made by the National Air Quality Officer (NAQO) regarding Eskom Holdings SOC Ltd. The appellants argue that granting postponements and suspensions of compliance with Minimum Emission Standards (MES) for several coal-fired power stations in the Highveld Priority Area is unlawful and violates environmental laws and constitutional rights to health.

This final synthesis report by the Centre for Environmental Rights provides strategic and technical guidance on managing sulphur dioxide (SO2) emissions from old solid fuel combustion plants in South Africa, specifically focusing on Eskom and Sasol facilities. The report utilizes a cost-benefit analysis (CBA) to recommend minimum emission standards (MES) based on plant lifetime and economic viability, concluding that reducing SO2 emissions is technologically feasible and provides significant net societal benefits through improved public health and macroeconomic growth.

A legal notice from MacRobert Inc, acting on behalf of ArcelorMittal South Africa (Pty) Ltd (AMSA), addressed to the Minister of Environment, Forestry and Fisheries regarding an appeal filed by the Centre for Environmental Rights. The notice argues that the appeal against the postponement of compliance timeframes for Minimum Emission Standards at the Vanderbijlpark facility was submitted late and is therefore invalid unless condonation is granted.

The Life After Coal campaign, comprising the Centre for Environmental Rights (CER), groundWork (gW), and Earthlife Africa (ELA), submitted formal objections on 28 August 2020 against Eskom's applications for alternative emission limits at the Medupi and Matimba power stations. The campaign argues that these requests are an unlawful attempt to circumvent South Africa's Minimum Emission Standards (MES) and violate constitutional rights to a healthy environment.

The Centre for Environmental Rights, acting for groundWork and Earthlife Africa NPC, sent a letter to the Minister of Environment, Forestry and Fisheries on 12 May 2020, extending the deadline for the government to provide written reasons for amending the Minimum Emission Standards (MES) for sulphur dioxide (SO2) regarding existing solid-fuel combustion installations.

The Centre for Environmental Rights, acting for groundWork and Earthlife Africa NPC, has formally requested written reasons from the South African Minister of Environment, Forestry and Fisheries regarding an amendment to the Minimum Emission Standards (MES). The amendment, published on 27 March 2020, doubles the permissible sulphur dioxide (SO2) limit for existing solid-fuel combustion installations, which the authors argue is unconstitutional and unlawful.

The Life After Coal campaign, comprising the Centre for Environmental Rights (CER), groundWork, and Earthlife Africa Johannesburg, submitted formal objections on 29 January 2020 to Eskom's applications for alternative emission limits at the Medupi and Matimba power stations. The campaign argues that the applications are procedurally and substantively unlawful, violate the South African Constitution and environmental laws, and rely on a flawed air quality modelling approach in a priority area already suffering from poor air quality.

A 2020 fact sheet from the Centro de Movilidad Sostenible detailing fuel quality standards (specifically sulfur levels and octane ratings) and emission standards for light-duty vehicles (LDV) across several Latin American and Caribbean countries.

The Centre for Environmental Rights (CER), representing the Life After Coal campaign and several environmental justice alliances, formally objects to a proposed amendment by the Department of Environment, Forestry and Fisheries to double the Sulphur Dioxide (SO2) Minimum Emission Standard (MES) for new plants in sub-category 1.1 from 500 mg/Nm3 to 1000 mg/Nm3. The CER argues that this weakening of standards is unlawful, violates the South African Constitution's right to a healthy environment, and would lead to significant premature deaths and exacerbated air pollution in priority areas.

A letter from the Centre for Environmental Rights (CER) to the Minister of Environmental Affairs demanding the withdrawal of an amendment to the List of Activities that weakened sulphur dioxide minimum emission standards for existing plants.

The Life After Coal campaign, led by the Centre for Environmental Rights (CER), formally objects to Eskom's application for the suspension, postponement, or alternative limits of Minimum Emission Standards (MES) for 10 coal-fired power stations. The submission argues that Eskom fails to meet the legal prerequisites of the 2017 National Framework for Air Quality Management, specifically regarding National Ambient Air Quality Standards (NAAQS) compliance and the prevention of direct adverse health impacts.

The Centre for Environmental Rights (CER), acting on behalf of several environmental campaigns and alliances, requested that the South African Department of Environmental Affairs urgently withdraw a provision in the amended List of Activities published on 31 October 2018. The CER argues that this provision improperly weakens the sulphur dioxide (SO2) minimum emission standards (MES) for existing solid-fuel combustion plants without public consultation.

The Centre for Environmental Rights (CER) submitted a formal request to Eskom on 8 October 2018 for records and reports concerning the Medupi and Kusile coal-fired power stations. The request focuses on environmental compliance, Flue Gas Desulphurisation (FGD) installation progress, water supply arrangements, and communications with the World Bank and African Development Bank.

The Centre for Environmental Rights (CER), acting as part of the Life After Coal campaign, submitted a formal objection to Eskom's application to postpone compliance with Minimum Emission Standards (MES) for 14 power stations. The submission argues that such postponements are legally impermissible because the power stations are located in priority areas where national ambient air quality standards (NAAQS) are not being met. The CER contends that the Background Information Document (BID) provided by Eskom is incomplete and misleading, and that the continued emissions cause severe health impacts and premature deaths in surrounding communities.

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.