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HOW CAN INDONESIA ACHIEVE WATER, ENERGY AND FOOD SECURITY WITHOUT ERODING ITS NATURAL CAPITAL?
This briefing note, produced by WCS Indonesia and the Global Canopy Programme, evaluates the coherence of Indonesia's water, energy, and food (WEF) security targets. It argues that while Indonesia aims for rapid economic growth and self-sufficiency, its 'business-as-usual' model of exploiting natural resources has led to severe environmental degradation, which now threatens the very security targets the government seeks to achieve. The document advocates for a WEF nexus approach to manage trade-offs between sector goals and forest conservation.
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Document type: Briefing
00206BB9DB98180921100544
A letter from the Acting Minister of Environmental Affairs of South Africa to the Centre for Environmental Rights acknowledging a study on Coal Independent Power Producers and stating the country's commitment to a science-based climate response and a mix of power generation technologies as per the Integrated Resource Plan (IRP).
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Document type: Statement
SKM_28720070115330
This briefing consists of the Practice Note and Heads of Argument filed by the Centre for Environmental Rights (CER) as an amicus curiae in the Supreme Court of Appeal case Global Environmental Trust & 2 Others vs Tendele Coal Mining (Pty) Ltd & 8 Others. The CER argues that mining operations require both a mining right under the Mineral and Petroleum Resources Development Act (MPRDA) and a separate environmental authorisation under the National Environmental Management Act (NEMA), challenging a lower court's ruling that an approved Environmental Management Plan (EMP) under the MPRDA suffices as environmental authorisation.
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Document type: Briefing
SKM_28720050814180
This document consists of the Appellants' Practice Note and Heads of Argument filed in the Supreme Court of Appeal of South Africa on 8 May 2020. The Appellants, including the Global Environmental Trust and the Mfolozi Community Environmental Justice Organisation, are appealing a High Court judgment that found in favour of Tendele Coal Mining (Pty) Ltd. The appeal centers on whether Tendele's mining operations at the Somkhele Mine were conducted lawfully without specific environmental authorisations under the National Environmental Management Act (NEMA), municipal land use approvals, waste management licences, and permits for the relocation of community graves.
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Document type: Briefing
1.2-annexures-2-78fa702fbab040ea.pdf
This document consists of a series of legal submissions, correspondence, and technical reports related to an appeal against the granting of a mining right to William Patrick Bower (Pty) Ltd (WPB) for a coal mine near Belfast, Mpumalanga. The materials include a hydrogeochemical study on acid mine drainage (AMD) and decant management, a responding statement from BirdLife South Africa (represented by the Centre for Environmental Rights), and an internal appeal from the Escarpment Environment Protection Group (EEPOG). The central disputes concern procedural unfairness in the consultation process, the inadequacy of environmental impact assessments—specifically regarding biodiversity and water quality—and the lack of a sustainable mine closure plan.
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Document type: Report
1.4-annexures-4-29c174f5574f969f.pdf
This document consists of several annexures related to two proposed coal mining projects in Mpumalanga, South Africa: the Lusthof Colliery and the WPB Colliery. The first part is a draft report from 2012 by Dr. Hugo van Zyl for Black Gold Coal Estates (BGCE) regarding the financial provisioning for a Reverse Osmosis Water Treatment Plant (WTP) at Lusthof Colliery, estimating a required provision of approximately R74.42 million to cover construction and 100 years of post-closure operation. The second part contains correspondence and reviews from 2013 to 2015 regarding the WPB Colliery, featuring objections from BirdLife South Africa and technical reviews by Golder Associates. These reviews highlight 'fatal flaws' in the WPB Colliery's water use license application, specifically the lack of adequate acid mine drainage (AMD) assessment, insufficient public participation, and flawed geochemical modelling for pollution mitigation.
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Document type: Report
CER’S COMMENTS ON THE PROPOSED AMENDMENTS TO THE ENVIRONMENTAL IMPACT ASSESSMENT REGULATIONS, LISTING NOTICE 1, LISTING NOTICE 2 AND LISTING NOTICE 3 OF THE ENVIRONMENTAL IMPACT ASSESSMENT REGULATIONS, 2014 FOR ACTIVITIES IDENTIFIED IN TERMS OF SECTION 24(2) AND 24D OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998, AS PUBLISHED IN GOVERNMENT GAZETTE NUMBER 43904 UNDER NOTICE NUMBER 1224 ON 13 NOVEMBER 2020
The Centre for Environmental Rights (CER) provides detailed comments and proposed amendments to the proposed changes to the Environmental Impact Assessment (EIA) Regulations, 2014, and associated Listing Notices. The CER focuses on improving public participation, ensuring comprehensive financial provisioning for environmental rehabilitation, and opposing 'catch-all' listings for extractive industries.
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Document type: Statement
11-4d604f093b78e1d1.pdf
This report, prepared by GCS Water and Environment (Pty) Ltd for the Centre for Environmental Rights (CER), reviews the Integrated Water Use License Application (IWULA) and the resulting license (IWUL) issued to Atha-Africa Ventures (Pty) Ltd for the proposed Yzermyn underground coal mine in Mpumalanga. GCS concludes that the specialist studies supporting the license are fundamentally flawed, containing significant data gaps and low-confidence modeling. The review highlights a high risk of irreversible damage to sensitive wetlands and groundwater resources, noting that the IWUL lacks sufficient conditions to mitigate these impacts and fails to authorize critical post-closure water treatment needs.
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Document type: Report
12-f99d03b7f1e2742e.pdf
This report by the Centre for Environmental Rights reviews the Integrated Water Use License Application (IWULA) and the resulting Integrated Water Use License (IWUL) for the proposed Yzermyn Underground Coal Mine. It identifies significant gaps in specialist studies regarding groundwater, hydrology, and wetlands, arguing that the IWUL was issued without sufficient information to mitigate environmental impacts. The document also includes a Socio-economic Impact Assessment and a Social and Labour Plan (SLP) detailing employment targets, skills development, and community impacts.
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Document type: Report
150424-aav-letter-to-dmr-c2c6afdad23d2855.pdf
A letter from Atha-Africa Ventures (Pty) Ltd (AAV) to the Department of Mineral Resources (DMR) requesting that a notice of appeal by the Centre for Environmental Rights (CER) be dismissed. AAV argues that the original mining right granting letter, which the CER appealed, was superseded and rendered null and void by a second granting letter issued by the Minister of Mineral Resources.
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Document type: Statement
161107-eskom-grounds-of-appeal-3341d66da8c1ef49.pdf
This document is an internal appeal submitted by groundWork, represented by the Centre for Environmental Rights (CER), against the deemed refusal by Eskom Holdings SOC Limited to provide records regarding its compliance with emission standards and the decommissioning of its coal-fired power stations.
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Document type: Statement
SKM_28720061815070
This document consists of the heads of argument filed on 17 June 2020 by four applicants (including the Mpukunyoni Traditional Council and labor unions) seeking admission as amicus curiae in an appeal before the Supreme Court of Appeal of South Africa. The applicants argue against a proposed interim interdict that would stop the mining operations of Tendele Coal Mining (Pty) Ltd, asserting that such a closure would cause disastrous socio-economic harm to the local community and the South African ferrochrome industry.
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Document type: Briefing
17-06-2021-cer-comments-on-the-draft-asm-policy-2021-f5fc80e02cd7b026.pdf
The Centre for Environmental Rights (CER) provides comments on the draft Artisanal and Small-Scale Mining (ASM) Policy 2021, arguing that ASM operators should be held to the same environmental, water, and health and safety standards as large-scale miners to prevent poverty and inequality caused by environmental degradation.
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Document type: Statement
SKM_28720072311360
This document consists of the heads of argument filed by Tendele Coal Mining (Pty) Limited (the First Respondent) in the Supreme Court of Appeal of South Africa. The filing is a response to arguments submitted by an amicus curiae (the Centre for Environmental Rights) regarding whether mining operations commencing before 8 December 2014 required both a mining right under the Mineral and Petroleum Resources Development Act (MPRDA) and a separate environmental authorisation under the National Environmental Management Act (NEMA).
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Document type: Briefing
2-cc55912e4e35173b.pdf
This legal document, submitted by the Centre for Environmental Rights (CER) on behalf of a Coalition, challenges the rezoning of the Yzermyn 96 HT farm from agricultural to mining purposes. The document details the environmental sensitivity of the Wakkerstroom area, the potential for irreparable harm to water resources and biodiversity, and the limited socio-economic benefits of the proposed Atha coal mine compared to the risks to local subsistence farmers and the eco-tourism economy.
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Document type: Report
2011-da-terblanche-q575-transgression-of-the-nwa-by-a-coal-washing-plant-and-municipal-enforcement-4fd0f8fff1900b48.pdf
This document is a draft written reply from the Minister of Water and Environmental Affairs to a National Assembly question (No. 575) regarding a coal washing plant's compliance with the National Water Act in the eMalahleni Municipality.
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Document type: Briefing
2014-05-30-fa1-sasol-approval-for-legal-action-340a8dc492f128d2.pdf
A formal approval document dated 19 May 2014, signed by Sasol executives, authorizing legal proceedings in the High Court of South Africa to review and set aside specific atmospheric emission regulations promulgated by the Minister of Water and Environmental Affairs.
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Document type: Statement
2014-05-30-fa11-s21-project-international-review-4d7ff58bb0ec9577.pdf
This report, produced for the South African Department of Environmental Affairs and Tourism (DEAT), provides an international review of air emission standards to support the implementation of Section 21 of the National Environmental Management: Air Quality Act (NEM:AQA). It analyzes regulatory frameworks in the United States, United Kingdom, and Australia (specifically New South Wales), with additional references to India, Japan, Poland, and China. The document recommends a phased approach to listing industrial activities and setting minimum emission standards based on Best Available Technology (BAT), while suggesting the integration of command-and-control measures with market-based mechanisms like emissions trading.
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Document type: Report
2014-05-30-fa12-s21-project-final-revew-report-ec28195dda07a12e.pdf
This document consists of a final review report and supporting meeting minutes and submissions regarding the implementation of listed activities and minimum emission standards (MES) under the National Environmental Management: Air Quality Act (AQA) of 2004 in South Africa. It proposes a phased approach to setting emission standards based on Best Available Technology (BAT), identifies priority industry sectors for initial listing, and discusses the establishment of national ambient air quality standards to protect public health and the environment.
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Document type: Report
2014-05-30-fa22-sasol-submision-on-standards-25-11-2008-8ac24d0908cbe521.pdf
This document is a submission by Synfuels regarding proposed emission standards for combustion installations. The author provides feedback on particulate matter, carbon monoxide, sulfur dioxide, and nitrogen oxide limits for both existing and new facilities, arguing for alignment with international standards and consideration of local resource constraints.
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Document type: Statement