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2014-05-30-fa46-natref-submission-05-2012-018e25d4b2c23688.pdf
A June 2012 submission by the Natref refinery to the South African Department of Environmental Affairs (DEA) regarding proposed Minimum Emission Standards (MES). Natref argues that inflexible national point source emission standards are impractical for existing facilities and proposes a 'bubble' approach to emissions management to ensure socio-economic sustainability and energy security.
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Document type: Report
2014-05-30-fa48-sasol-h2s-proposal-a20a27011aaef7b4.pdf
This report by Sasol outlines the company's proposal to the Department of Environmental Affairs (DEA) regarding hydrogen sulphide (H2S) emission standards for its Synfuels facility in Secunda. Sasol argues that the published 2010 standard of 1,000 mg/Nm³ is unachievable within the required timeframes due to technical constraints, the uniqueness of the Sasol process, and market limitations for sulphuric acid. The company proposes alternative standards based on stack averaging and specific points of compliance to ensure practical and sustainable air quality improvement.
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Document type: Report
2014-05-30-fa52-natref-submission-to-dea-10-2012-530e4ff6e1ac4773.pdf
This October 2012 submission from the Natref refinery to the South African Department of Environmental Affairs (DEA) argues that the proposed Minimum Emission Standards (MES) are technically and socio-economically unsustainable for existing inland refineries. Natref advocates for a "bubble" approach to emissions management rather than a point-source approach and requests separate, less stringent limits for existing facilities compared to new plants.
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Document type: Report
2014-05-30-fa57-email-from-sasol-to-dea-20-11-2013-2db5966aa2d5547e.pdf
This document is a submission from Sasol to the South African Department of Environmental Affairs (DEA) detailing the company's objections to the requirement that existing industrial plants meet 'new plant standards' for emissions by April 1, 2020. Sasol argues that retrofitting old facilities is often technically impossible due to space and configuration constraints, economically unviable, and potentially counterproductive to other environmental goals, such as carbon footprint reduction and water conservation.
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Document type: Report
2014-05-30-fa61-revised-busa-submission-32b0a89bc77f0c70.pdf
This document is a revised submission by Business Unity South Africa (BUSA) providing detailed comments and proposed amendments to a draft Notice regarding activities resulting in atmospheric emissions. BUSA argues that the proposed emission limits and compliance timeframes are often technically and financially unfeasible, potentially harming the economic viability of the industrial and mining sectors during a period of manufacturing decline.
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Document type: Statement
2014-05-30-fa65-green-room-issues-15-05-2013-c19ba92f885f774b.pdf
This briefing document outlines technical and regulatory issues arising from a May 15, 2013, workshop between the Department of Environmental Affairs (DEA) and industry stakeholders regarding the Section 21 emission standards. It focuses on refining activity descriptions, adjusting emission limits for specific industrial processes, and addressing the legal and practical implications of including 'use of' and 'storage' in the listed activities.
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Document type: Briefing
annexure-1-9c39c3da6f8e0daf.pdf
The Centre for Environmental Rights (CER), acting for the Highveld Environmental Justice Network (HEJN), groundWork (gW), and Earthlife Africa (ELA), submitted preliminary objections and recommendations regarding the draft Air Quality Management Plan (AQMP) and draft Air Quality Management By-laws for the Nkangala District Municipality (NDM). The CER argues that the public participation process was procedurally unfair due to insufficient notice and comment periods. Substantively, the CER identifies critical gaps in the draft AQMP, including a lack of enforcement strategies, insufficient technical capacity within the NDM, and misalignment with the Highveld Priority Area (HPA) goals. The CER also proposes significant amendments to the draft by-laws to strengthen dust control, clarify authorization procedures, and ensure stricter local emission standards.
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Document type: Statement
SUBMISSIONS ON THE REVISED DRAFT AIR QUALITY MANAGEMENT PLAN “ANNEXURE 2”
The Centre for Environmental Rights (CER) submitted comments on the revised draft Air Quality Management Plan (AQMP) for the Nkangala District Municipality (NDM). The CER argues that the plan is overly ambitious given the NDM's lack of capacity and resources, fails to align with the Highveld Priority Area (HPA) AQMP, and contains significant technical errors in its air quality modelling and data.
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Document type: Statement
annexure-25-2b1bd8ee8d20586e.pdf
This 2013 government notice from the South African Department of Environmental Affairs declares small boilers as controlled emitters under the National Environmental Management: Air Quality Act, 2004. It establishes specific emission standards for particulate matter and sulphur dioxide across various fuel types, defines compliance timeframes for new and existing boilers, and mandates annual emissions reporting to air quality officers.
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Document type: Statement
annexure-b-1-ae05ca5f3c13a16f.pdf
A letter from the Centre for Environmental Rights (CER) to the South African Minister of Health, requesting the Department of Health's participation in the Highveld Priority Area (HPA) Multi-Stakeholder Reference Group meetings to address the severe health impacts of air pollution.
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Document type: Statement
APPEAL TO THE MINISTER OF ENVIRONMENTAL AFFAIRS AND TOURISM
The Vaal Environmental Justice Alliance (VEJA) and groundWork have appealed a decision by the National Air Quality Officer (NAQO) to grant ArcelorMittal South Africa (AMSA) postponements and alternative emission limits for Hydrogen Sulphide (H2S) at its Vanderbijlpark facility. The appellants argue that the granted limits are unlawfully weaker than existing plant standards and that AMSA's history of environmental non-compliance makes it unfit to receive such leniency.
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Document type: Statement
arcelormittal-newcastle-decision-applicant-9d9900b06cf24d5f.pdf
A letter from the South African Department of Environmental Affairs to ArcelorMittal South Africa Limited (Newcastle Steel Works) detailing the National Air Quality Officer's decisions regarding applications for alternative limits and the postponement of compliance time-frames for minimum emission standards under the National Environmental Management: Air Quality Act 39 of 2004.
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Document type: Statement
00206BBA608D200323172756
A statement from the South African Department of Environmental Affairs to the Amajuba District Municipality regarding the application by ArcelorMittal South Africa Limited (Newcastle Steel Works) for alternative limits or postponed compliance with the National Environmental Management: Air Quality Act 39 of 2004 minimum emission standards.
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Document type: Statement
00206BBA608D200323172746
A decision letter from the South African Department of Environmental Affairs granting ArcelorMittal South Africa Limited (Pretoria Steel Works) a suspension of compliance time-frames for specific minimum emission standards under the National Environmental Management: Air Quality Act 39 of 2004 for the period from 1 April 2020 to 31 March 2030.
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Document type: Statement
00206BBA608D200323172733
A statement from the South African Department of Environmental Affairs granting ArcelorMittal South Africa Limited (Pretoria Steel Works) a suspension of compliance time-frames for certain minimum emission standards under the National Environmental Management: Air Quality Act 39 of 2004 for the period from 1 April 2020 to 31 March 2030.
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Document type: Statement
00206BBA608D200323175100
A decision letter from the South African Department of Environmental Affairs to the Sedibeng District Municipality regarding the application by ArcelorMittal South Africa Limited (Vanderbijlpark Steel Works) for alternative emission limits or postponed compliance time-frames under the National Environmental Management: Air Quality Act 39 of 2004.
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Document type: Statement
arm-ghg-report-c62ac965d14cdb23.pdf
This document is a greenhouse gas (GHG) emissions data submission for the period of 1 January 2018 to 31 December 2018, provided by African Rainbow Minerals Limited on 29 March 2019.
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Document type: Report
cover-letter-cer-submissions-on-ndm-aqmp-by-law-_27-5-15-f703c28e373a7d09.pdf
A cover letter from the Centre for Environmental Rights (CER) submitting formal comments on the draft Air Quality Management Plan (AQMP) and Air Quality Management By-law for the Nkangala District Municipality on behalf of the Highveld Environmental Justice Network, groundWork, and Earthlife Africa, Johannesburg.
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Document type: Statement
dd24-dd25-86f635fc7b235fc4.pdf
This document consists of an internal appeal filed by the Centre for Environmental Rights (CER) on behalf of the South Durban Community Environmental Alliance (SDCEA) and the subsequent ruling by the eThekwini Metropolitan Municipality. The appeal challenged the Municipality's refusal to grant access to Atmospheric Emission Licences (AELs) and compliance reports for the SAPREF (Shell and BP) and Engen petroleum refineries, which the Municipality had withheld citing the protection of third-party commercial information under the Promotion of Access to Information Act (PAIA). The Appeal Authority ultimately upheld the refusal, ruling that the information was commercially sensitive and that the public interest override was not sufficiently substantiated.
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Document type: Statement
dd26-part-1-of-2-7afc7a97619f5abb.pdf
This document is an Atmospheric Emission Licence (WCCT006) issued by the City of Cape Town to the Chevron Refinery in Cape Town. Issued on 31 March 2014 and valid until 31 March 2079, the licence authorizes various listed activities related to petroleum refining, including liquid and gas combustion, catalytic cracking, sulphur recovery, and the storage and handling of petroleum products. It details the refinery's operational processes, raw material capacities, and general conditions for compliance with the National Environmental Management: Air Quality Act, 2004.
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Document type: Report