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Economic Consumer Cost and Pollution Impacts of Federal Energy Policy Changes
This report by Energy Innovation uses the Energy Policy Simulator to model the economic, public health, and energy cost impacts of federal policy changes enacted during the second Trump administration and the 119th Congress between 2026 and 2040. The analysis focuses on seven key policy shifts, including the One Big Beautiful Bill Act (OBBBA), the repeal of EPA greenhouse gas and tailpipe emissions standards, and the cancellation of the $7 billion Solar for All grant program.
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Document type: Report
SUBMISSIONS ON ESKOM’S APPLICATION FOR EXEMPTION IN TERMS OF SECTION 59 WITH THE MINIMUM EMISSION STANDARDS FOR 8 OF ITS COAL-FIRED POWER STATIONS
The Centre for Environmental Rights (CER), on behalf of groundWork and Earthlife Africa, submits a formal objection to Eskom's application for exemptions from Minimum Emission Standards (MES) for eight coal-fired power stations under section 59 of the Air Quality Act (AQA). The submission argues that these exemptions violate the constitutional right to a healthy environment, particularly for residents in Priority Areas, and that Eskom has failed to justify its 14-year delay in achieving compliance.
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Document type: Statement
A Technology-Neutral Emissions Standard for Clean Industrial Heat
This policy design brief by Energy Innovation proposes a technology-neutral emissions standard for industrial heat to reduce greenhouse gas emissions and conventional pollutants. The author outlines specific design considerations for lawmakers to ensure the standard is simple to administer, incentivizes efficiency, and provides long-term certainty for industrial investment.
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Document type: Policy brief
LETTER OF CONFIRMATION OF APPOINTMENT OF ATTORNEYS OF RECORD
A letter from groundWork Trust confirming the appointment of the Centre for Environmental Rights (CER) as its attorneys of record to appeal a decision regarding ArcelorMittal’s Vanderbijlpark facility.
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Document type: Statement
AIR QUALITY IMPACTS AND HEALTH EFFECTS DUE TO LARGE STATIONARY SOURCE EMISSIONS IN AND AROUND SOUTH AFRICA’S MPUMALANGA HIGHVELD PRIORITY AREA (HPA)
This report provides an air-pollution dispersion model and health risk assessment for 14 industrial facilities in and around South Africa's Mpumalanga Highveld Priority Area (HPA). The analysis compares actual 2016 emissions against a scenario where facilities comply with the 2020 Minimum Emissions Standards (MES), finding that current emissions cause significant early deaths and exceed multiple international air quality guidelines.
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Document type: Report
OPPOSITION TO THE ESTABLISHMENT OF A PANEL OF EXPERTS TO PROVIDE STRATEGIC AND TECHNICAL GUIDANCE TOWARDS MANAGEMENT OF SULPHUR DIOXIDE EMISSIONS FROM EXISTING PLANTS
The Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, represented by the Centre for Environmental Rights, groundWork, and Earthlife Africa Johannesburg, formally opposes the Department of Environmental Affairs' (DEA) plan to establish an expert panel to provide guidance on managing sulphur dioxide (SO2) emissions from existing power plants. The campaign argues that such a panel is unnecessary, would delay compliance with Minimum Emission Standards (MES), and lacks a legislative basis for potentially weakening those standards.
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Document type: Statement
President Trump’s State of the Union Misses the Mark
Dr. Andrew Steer, President & CEO of the World Resources Institute, critiques President Trump's first State of the Union address for failing to link extreme weather to climate change and for prioritizing fossil fuels over renewable energy markets.
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Document type: Statement
SUBMISSIONS ON THE BACKGROUND INFORMATION DOCUMENT FOR ESKOM’S POSTPONEMENT APPLICATION IN RESPECT OF THE 2015 MINIMUM EMISSION STANDARDS (MES) TIMEFRAMES FOR ESKOM’S MEDUPI AND MATIMBA POWER STATIONS
The Life After Coal campaign opposes Eskom's application to postpone sulphur dioxide emission standards at the Medupi and Matimba power stations, citing a history of non-compliance, failure to install required abatement technology, and a lack of comprehensive health risk assessments for affected communities in the Waterberg District Municipality.
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Document type: Statement
WRI Response to the 2014 State of the Union Address
The World Resources Institute (WRI) issued a statement responding to President Obama's 2014 State of the Union address, supporting the administration's plan to enact new emissions standards for existing power plants and emphasizing the economic benefits of transitioning to a low-carbon economy.
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Document type: Statement
2014-05-30-fa33-sapia-letter-to-dea-28-08-2009-163f0dfb691f3316.pdf
A letter from the South African Petroleum Industry Association (SAPIA) to the Director-General of Environmental Affairs dated 28 August 2009, providing comments and proposed amendments to the Listed Activities and Minimum Emission Standards published in Government Notice No. 32434 of 24 July 2009.
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Document type: Statement
2014-05-30-fa39-sapia-letter-to-dea-30-04-2010-0adb799e383a26a3.pdf
A letter from the South African Petroleum Industry Association (SAPIA) to the Department of Environmental Affairs dated 30 April 2010, expressing concerns over the final 'List of Activities' published under the National Environmental Management: Air Quality Act, 2004. SAPIA argues that the final legislation deviates significantly from the draft version without adequate consultation or explanation, specifically regarding sulphur dioxide limits, timelines for existing refineries, and vapour recovery mandates.
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Document type: Statement
ael_lethabo-april-2015-06bae8eaa33819d7.pdf
This document is an Atmospheric Emissions Licence (AEL) issued by the Fezile Dabi District Municipality to Eskom Holdings SOC Ltd for the Lethabo Power Station. Issued on 1 April 2015 and valid until 31 March 2020, the licence regulates emissions from solid fuel combustion and the storage of petroleum products, specifying minimum emission standards for pollutants and reporting requirements within the Vaal Triangle Airshed Priority Area.
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Document type: Statement
Comments on the series of Applications for Suspension of the Minimum Emissions Standards (MES) Compliance Timeframes for Various Eskom Coal-Fired Power Plants
This document provides a technical critique by consultant Dr. Ranajit (Ron) Sahu regarding Eskom's applications to suspend compliance timeframes for Minimum Emissions Standards (MES) at various coal-fired power plants. The author argues that Eskom's justifications for delays—including plant decommissioning, water scarcity, and capital costs—are untenable or substantially inflated, and suggests alternative technologies to achieve emission reductions.
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Document type: Report
KM_C454e-20200915142604
A letter from the Vaal Environmental Justice Alliance (VEJA) dated 15 September 2020, confirming the appointment of the Centre for Environmental Rights (CER) as its attorneys of record to appeal a decision regarding emission standards for an ArcelorMittal facility.
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Document type: Statement
annexure-h_eskoms-response-to-deas-additonal-information-request-in-terms-of-the-postponement-applications_camden-power-station-4cfac5ed4422baee.pdf
This document is a response from Eskom to the Department of Environmental Affairs (DEA) regarding a request for additional information on the postponement application for the Camden Power Station to comply with Minimum Emission Standards (MES). Eskom states that the station will not comply with 'new plant' standards for particulate matter (PM), sulfur dioxide (SO2), or nitrogen oxides (NOx) before its expected decommissioning between 2020 and 2023.
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Document type: Briefing
annexure-h_eskoms-response-to-deas-additonal-information-request-in-terms-of-the-postponement-applications_hendrina-power-station-d57cbbdc7c872fea.pdf
This briefing, dated 17 July 2014, is a response from Eskom to the South African Department of Environmental Affairs (DEA) regarding a postponement application for the Hendrina Power Station to comply with Minimum Emission Standards (MES). Eskom outlines current stack emission limits, its lack of plans to upgrade the station for certain pollutants, and provides ambient air quality monitoring data showing non-compliance for particulate matter.
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Document type: Briefing
annexure-h_eskoms-response-to-deas-additonal-information-request-in-terms-of-the-postponement-applications_komati-power-station-75b77503ae5b7ee9.pdf
Eskom's 2014 response to the DEA regarding the Komati Power Station's request to postpone compliance with Minimum Emission Standards (MES). Eskom states it has no plans to upgrade the station to meet 'new plant' limits for PM, SO2, and NOx because the station is old (commissioned 1961-1966) and slated for decommissioning between 2024 and 2028. While the station complies with ambient SO2 and NOx standards, it is in non-compliance with ambient PM10 standards, recording between 82 and 162 exceedances of the 24-hour limit per year. Eskom argues that further emission reductions at Komati would not meaningfully improve ambient PM levels as the station's contribution is small compared to total levels.
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Document type: Briefing
annexure-h_eskoms-response-to-deas-additonal-information-request-in-terms-of-the-postponement-applications_lethabo-power-station-8abc67952e171fd4.pdf
This document is a letter from Eskom to the Department of Environmental Affairs (DEA) dated 17 July 2014, providing additional information to support a postponement application for the Lethabo Power Station's compliance with Minimum Emission Standards (MES). Eskom outlines current stack emission limits, argues that full compliance by 2015 and 2020 is not practically feasible, and provides ambient air quality monitoring data and a register of public complaints regarding pollution.
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Document type: Briefing
00206B3D20B8201026111202
This document is a decision by the Director of Appeals and Legal Review within the South African Department of Environment, Forestry and Fisheries regarding a request for condonation for the late filing of an appeal. The appeal concerns a decision to grant ArcelorMittal South Africa a suspension from complying with Minimum Emission Standards (MES) at its facility in Vanderbijlpark.
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Document type: Statement
Health impacts of Eskomʼs non-compliance with minimum emissions standards
This report analyzes the public health and economic consequences of Eskom's failure to comply with South Africa's Minimum Emissions Standards (MES). It compares various compliance scenarios, concluding that Eskom's current retrofit plan provides minimal health benefits due to a failure to address sulphur dioxide (SO2) emissions, and that full compliance or the adoption of Best Available Technology (BAT) would significantly reduce premature deaths and economic losses.
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Document type: Report