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OPPOSITION TO THE ESTABLISHMENT OF AN EXPERT PANEL ON SULPHUR DIOXIDE (SO2) ABATEMENT SOLUTIONS
The Centre for Environmental Rights (CER), representing groundWork, Earthlife Africa Johannesburg, the Highveld Environmental Justice Network, and the Vaal Environmental Justice Alliance, opposes the Department of Environmental Affairs' (DEA) proposal to create an expert panel to address sulphur dioxide (SO2) abatement. The CER contends that Eskom and Sasol, the country's largest polluters, are using the proposal to avoid compliance with minimum emission standards (MES) and to secure 'rolling postponements'. The document argues that the necessary solution—retrofitting plants with flue gas desulphurisation (FGD) technology or decommissioning non-compliant plants—has already been established through a five-year multi-stakeholder process. Furthermore, it highlights that South African SO2 standards are significantly weaker than those in other developing and developed nations, and that the DEA has no legislative authority to weaken the MES based on industry claims of economic infeasibility.
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Document type: Statement
URGENT STEPS NEEDED TO ADDRESS AIR POLLUTION IN THE HIGHVELD PRIORTY AREA
The Centre for Environmental Rights (CER) has called on the Department of Environmental Affairs (DEA) to take urgent action against air pollution in the Highveld Priority Area (HPA). The letter criticizes the DEA's dismissal of health impact studies linking Eskom and Sasol emissions to thousands of deaths and respiratory illnesses. It further demands an end to 'rolling postponements' of minimum emission standards (MES), a response to the 'Broken Promises' report, and updates on the Highveld Priority Area Air Quality Management Plan (AQMP) goals and its Mid-Term Review.
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Document type: Statement
Clean Air Task Force Initial Comments on Draft Accounting and Permanence Protocol for Carbon Capture and Geologic Sequestration under Low Carbon Fuel Standard
CATF argues that the California Air Resources Board's draft protocol for carbon capture and geologic sequestration relies on arbitrary timeframes, specifically a 100-year post-closure monitoring requirement, which may deter investment. CATF proposes a performance-based approach where site closure is determined by demonstrating CO2 plume stability and storage integrity rather than a fixed duration. The document highlights the different risk profiles of saline brine storage versus enhanced oil recovery (EOR) and cites the Mountaineer project in West Virginia as an example where stability was demonstrated in three years, allowing for early closure.
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Document type: Statement
Ten key short-term sectoral benchmarks to limit warming to 1.5°C
The report establishes ten sectoral benchmarks for 2020–2025 to align with the 1.5°C goal of the Paris Agreement, emphasizing the need for large-scale technology diffusion and sector transformations over marginal efficiency gains. Key targets include a total ban on new coal power plants, a 30% reduction in emissions from the existing coal fleet by 2025, and ensuring all new buildings are fossil-free and near-zero energy by 2020.
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Document type: Report
The Carbon-Free City Handbook: Industry
The document identifies that industry accounts for 7% of carbon emissions in major cities and proposes three primary actions to mitigate this: implementing clean industrial heat solutions, replacing inefficient motors with high-efficiency models, and establishing voluntary energy management and operator training programs. It emphasizes the need for cities to partner strategically with corporate residents due to limited jurisdictional control.
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Document type: Guide
Environmental Justice for Delaware
The report finds that seven communities in northern New Castle County, Delaware—characterized by higher poverty and proportions of people of color—face substantially higher cancer and respiratory health risks than the affluent, predominantly White community of Greenville and the state average. These risks are driven by toxic air pollutants, specifically formaldehyde and acrolein, and proximity to high-risk chemical facilities and contaminated waste sites. The document recommends stricter chemical safety regulations, enhanced fenceline monitoring, and the implementation of comprehensive health-impact assessments to address these environmental justice disparities.
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Document type: Executive summary
Taking Carbon Capture to the Next Level
The author advocates for the FUTURE Act, asserting that carbon capture utilization and storage (CCUS) is a "critical-path technology" for climate change mitigation, particularly for power plants and industrial emissions. The document argues that current tax credits are ineffective due to low credit levels and caps, and that the proposed legislation would drive innovation and cost reduction by raising credit levels and implementing time-limits. The author notes broad bi-partisan and cross-sector support for the bill, including from energy companies, labor unions, and environmental groups.
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Document type: Statement
DEPARTMENT OF ENVIRONMENTAL AFFAIRS BRIEFING TO PORTFOLIO COMMITTEE ON ENVIRONMENTAL AFFAIRS: ENFORCEMENT OF MINIMUM EMISSION STANDARDS IN THE PRIORITY AREAS; THE HIGHVELD REPORT AND IMPLEMENTATION OF ITS RECOMMENDATIONS; AND AIR QUALITY IN PRIORITY AREAS AND THE STATUS OF AIR QUALITY MONITORING STATIONS
The Centre for Environmental Rights (CER) argues that the Highveld Priority Area (HPA) has failed to meet national ambient air quality standards (NAAQS) despite a decade of management. The CER highlights that postponements of minimum emission standards (MES) granted to Eskom and Sasol have hindered progress and suggests that Eskom may be violating even its postponed standards. Furthermore, the CER criticizes the state of South Africa's air quality monitoring network, claiming that a majority of stations produce no data and very few produce quality-assured data. The document urges the Portfolio Committee to question the DEA on its enforcement actions, the legality of 'rolling postponements', and the decline in the number of reporting monitoring stations.
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Document type: Statement
A Fair EU ETS Revision REMOVING FAVOURITISM AND DISCRIMINATION FROM THE EU’S CARBON MARKET
The policy brief critiques the proposed EU ETS revision, arguing that over-generous free allowances to industrial sectors—particularly the steel industry—create windfall profits and deprive the public of potential auctioning revenues. It recommends increasing the Linear Reduction Factor to 4.2% to align with Paris Agreement goals, establishing a Just Transition Fund for workers, and shifting toward full auctioning to fund low-carbon innovation and support citizens.
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Document type: Policy brief
EU court ruling on pollution freebies sends strong message ahead of final emissions trading talks
Carbon Market Watch calls for the curtailment of free carbon allowances in the EU ETS following a court ruling requiring ArcelorMittal to return wrongfully received permits. The organization warns that current trialogue negotiations may result in the allocation of an additional 300 to 775 million free permits for heavy industry, contradicting the 'polluter pays' principle. The text advocates for increased auctioning of permits, the inclusion of importers in emission costs, and the potential introduction of a carbon tax to drive industrial decarbonization.
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Document type: Statement
PRELIMINARY COMMENTS ON THE DRAFT MID-TERM REVIEW OF THE HIGHVELD PRIORITY AREA AIR QUALITY MANAGEMENT PLAN
The Centre for Environmental Rights (CER) argues that the draft mid-term review (MTR) of the Highveld Priority Area (HPA) Air Quality Management Plan (AQMP) is methodologically flawed, outdated, and fails to demonstrate progress toward its goals. The CER highlights widespread non-compliance with national ambient air quality standards (NAAQS), a deteriorating monitoring network, and significant data gaps in industrial emissions reporting. It specifically criticizes the lack of functional monitoring stations and the failure of key industrial facilities to reduce emissions, concluding that the overall objective of achieving NAAQS compliance in the HPA is not being met.
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Document type: Statement
An International View on Decisions before the European Parliament on the ETS Post 2020
International researchers advocate for the strengthening of the EU ETS post-2020, emphasizing the need to address structural surpluses and ensure a full carbon price pass-through for basic materials like steel and cement to drive innovation and global policy alignment.
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Document type: Statement
Kemper in Perspective
The author asserts that the $7 billion cost of the Kemper plant in Mississippi is attributable to the first-of-a-kind TRIG gasifier and construction issues, not the Selexol carbon capture technology, which is a well-established process used in over 110 projects. The document contrasts Kemper with the Petra Nova project in Texas, which was completed on budget as a retrofit. Kemper is presented as globally significant because it demonstrates the storage side of coal gasification, offering a potential model for coal-to-chemicals plants in China to stop venting CO2. Domestically, the project demonstrates the expandability of the U.S. CO2 pipeline network. The author concludes by calling for Congressional incentives, such as production tax credits, to accelerate the deployment of carbon capture in the power and industrial sectors.
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Document type: Statement
Double Jeopardy in Houston
The report identifies a 'double jeopardy' for residents of Harrisburg/Manchester and Galena Park in east Houston, who face both higher daily exposure to toxic air pollutants and greater proximity to high-risk chemical facilities than residents of West Oaks/Eldridge and Bellaire in west Houston. This disparity results in significantly higher cancer and respiratory illness risks for east Houston residents, exacerbated by a lack of comprehensive zoning laws and socioeconomic determinants.
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Document type: Executive summary
REQUEST FOR THE DEPARTMENT OF HEALTH TO PARTICIPATE AS A STAKEHOLDER IN THE HIGHVELD PRIORITY AREA MULTI-STAKEHOLDER REFERENCE GROUP MEETINGS
The Centre for Environmental Rights (CER) and groundWork are urging the South African Department of Health to join the Highveld Priority Area (HPA) Multi-Stakeholder Reference Group (MSRG). They argue that the Department of Health's involvement is critical given the severe health burden caused by air pollution in the HPA, particularly from Eskom's coal-fired power stations. The document cites data suggesting thousands of premature deaths and significant IQ loss due to mercury emissions, as well as the economic costs of these health impacts, to justify the need for health officials to collaborate on air quality solutions.
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Document type: Statement
Request for Review of the Michigan Department of Environmental Quality and Michigan Department of Health and Human Services’ Compliance with Title VI of the Civil Rights Act of 1964 and Section 504 of the Rehabilitation Act of 1973
A coalition of organizations and individuals requested federal civil rights reviews of MDEQ and MDHHS, alleging that the Flint water crisis and pollution in Wayne County demonstrate a pattern of environmental injustice. The signatories argue that MDEQ failed to implement required corrosion control and manipulated lead testing, while MDHHS failed to respond to public health spikes and provided inadequate emergency services to people with disabilities and those with limited English proficiency.
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Document type: Statement
Inclusion of Consumption of carbon intensive materials in emissions trading – An option for carbon pricing post-2020 Report
The report proposes 'Inclusion of Consumption' (IoC) as a way to ensure carbon prices are reflected in the cost of materials like steel and cement, which are currently shielded by free allowance allocations in emissions trading schemes. By adding a charge to the consumption of these materials based on benchmarks, the IoC aims to incentivize material efficiency and innovation without harming competitiveness. The authors argue that IoC is administratively feasible, compliant with WTO law, and qualifies as an environmental regulation under EU law.
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Document type: Report
2015 EU ETS Emissions analysis from EC data
The 2015 EU ETS emissions fell by 0.6% to 1802mt, driven by a 0.6% decrease in power and heat emissions and a 0.3% decrease in industrial emissions. Notable national trends include a 23% drop in UK coal power emissions and an 11% increase in Netherlands power emissions due to new coal plants. The report highlights a long-term trend of renewables displacing fossil fuels in the European power sector.
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Document type: Report
Carbon leakage myth buster
The document argues that the EU ETS "carbon leakage" rules have led to massive windfall profits for French industrial companies while depriving the government of significant auctioning revenues. Between 2008 and 2014, French energy-intensive companies generated approximately €2.7 billion in windfall profits, with Bersillon, Total, and Lafarge being the top beneficiaries. The brief contends that these subsidies reduce incentives for decarbonization and that the Paris agreement will mitigate future leakage risks. It recommends phasing out free allocations in favor of 100% auctioning and implementing a tiered approach to target support only where truly necessary.
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Document type: Policy brief
Industry windfall profits from Europe’s carbon market
The document analyzes how the 'carbon leakage' mechanism in the EU ETS allowed heavy industry in 19 European countries to earn over €24 billion in windfall profits between 2008 and 2014. It contends that these subsidies reduce incentives for decarbonization and deprive governments of auctioning revenues, while evidence for actual carbon leakage remains absent. The brief recommends phasing out free allocations in favor of 100% auctioning to fund low-carbon innovation.
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Document type: Policy brief