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NEDBANK’S ROLE IN FINANCING PROPOSED NEW COAL-FIRED POWER PLANTS
The Centre for Environmental Rights (CER), writing on behalf of the Life After Coal Campaign, urges Nedbank to withdraw financial support for the Thabametsi and Khanyisa coal-fired power plants. The letter argues that these projects are not 'least-cost' options, face significant legal challenges regarding environmental and generation licenses, and would cause severe health and climate impacts in South Africa.
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Document type: Statement
STANDARD BANK’S ROLE IN FINANCING PROPOSED NEW COAL-FIRED POWER PLANTS
A letter from the Centre for Environmental Rights (CER), on behalf of the Life After Coal Campaign, urging Standard Bank to withdraw financial support for the proposed Thabametsi and Khanyisa coal-fired power plants in South Africa.
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Document type: Statement
SUBMISSIONS ON THE BACKGROUND INFORMATION DOCUMENT (BID) FOR ESKOM’S APPLICATION FOR POSTPONEMENT OF THE MINIMUM EMISSION STANDARDS (MES) FOR 14 OF ITS COAL AND LIQUID FUEL-FIRED POWER STATIONS
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.
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Document type: Statement
THE DEVELOPMENT BANK OF SOUTHERN AFRICA’S ROLE IN FINANCING PROPOSED NEW COAL-FIRED POWER PLANTS
The Centre for Environmental Rights (CER), writing on behalf of the Life After Coal Campaign, has requested that the Development Bank of Southern Africa (DBSA) clarify its role in financing the Thabametsi and Khanyisa coal-fired power plants. The CER argues that financing these projects would be unreasonable due to their high greenhouse gas emissions, negative impacts on water and air quality, and the fact that South Africa currently has surplus base supply capacity.
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Document type: Statement
SUBMISSIONS ON THE AMENDMENTS TO THE NATIONAL DUST CONTROL REGULATIONS 2013 PUBLISHED IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT: AIR QUALITY ACT, 2004 (AQA)
The Centre for Environmental Rights (CER), representing various non-governmental and community-based organisations, submitted comments to the Department of Environmental Affairs (DEA) regarding the 2018 Draft Amendments to the National Dust Control Regulations 2013. The CER argues that the draft regulations remain inadequate for protecting human health and the environment, particularly for mining-affected communities, and calls for more rigorous enforcement, better monitoring methods, and the inclusion of specific health-related analyses for toxic dust.
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Document type: Statement
RESPONSE TO MINISTER’S STATEMENT IN RELATION TO THE PROPOSED THABAMETSI & KHANYISA IPP COAL-FIRED POWER STATIONS
A letter from the Life After Coal Campaign and Greenpeace Africa to the South African Minister of Energy, objecting to the proposed Thabametsi and Khanyisa coal-fired independent power producer (IPP) projects. The authors argue that these projects are legally precarious, environmentally damaging, and economically unnecessary compared to renewable energy alternatives.
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Document type: Statement
OPPOSITION TO THE ESTABLISHMENT OF AN EXPERT PANEL ON SULPHUR DIOXIDE (SO2) ABATEMENT SOLUTIONS
The Centre for Environmental Rights (CER), representing several environmental justice organizations, formally opposes the Department of Environmental Affairs' (DEA) proposal to establish an expert panel to find solutions for sulphur dioxide (SO2) abatement. The CER argues that such a panel would unnecessarily delay compliance with Minimum Emission Standards (MES), duplicate previous multi-stakeholder processes, and potentially lead to an unlawful weakening of environmental standards for major polluters Eskom and Sasol.
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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), representing several environmental justice organizations, issued a formal letter to the Director-General of the Department of Environmental Affairs (DEA) on 26 February 2018. The letter demands urgent action to address air pollution in the Highveld Priority Area (HPA), specifically criticizing the DEA's handling of minimum emission standards (MES) compliance, its failure to respond to the 'Broken Promises' report, and the health impacts of emissions from Eskom and Sasol.
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Document type: Statement
SUBMISSIONS ON THE BACKGROUND INFORMATION DOCUMENT (BID) FOR ESKOM’S SECOND POSTPONEMENT APPLICATION IN RESPECT OF THE 2015 MINIMUM EMISSION STANDARDS (MES) FOR TUTUKA POWER STATION
The Centre for Environmental Rights (CER), on behalf of the Life After Coal campaign and the Highveld Environmental Justice Alliance Network (HEJN), submitted formal objections to Eskom's Background Information Document (BID) regarding a second postponement application for Minimum Emission Standards (MES) at the Tutuka Power Station. The submission argues that the application is legally impermissible because Tutuka is located in the Highveld Priority Area (HPA), where ambient air quality does not comply with National Ambient Air Quality Standards (NAAQS), a prerequisite for any postponement. The CER further contends that Eskom's request for a "rolling postponement" is equivalent to an illegal exemption and that the BID intentionally withholds critical information regarding pollutants, timeframes, and health impacts to mislead the public and decision-makers.
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Document type: Statement
LIFE AFTER COAL CAMPAIGN - ESKOM’S NON-COMPLIANCE WITH OBLIGATIONS TO PROTECT HUMAN HEALTH AND THE ENVIRONMENT REMAINS A MATERIAL LIABILITY
A letter from the Life After Coal Campaign to the Chairman of Eskom's Board of Directors, arguing that Eskom's reliance on coal-fired power is economically unsustainable and creates severe liabilities regarding human health, water, and the environment.
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Document type: Statement
RELEVANT INFORMATION CONCERNING ESKOM – A STUDY BY MERIDIAN ECONOMICS
The Centre for Environmental Rights (CER), representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted a letter to the Portfolio Committee on Environmental Affairs on 27 November 2017. The letter highlights findings from a study by Meridian Economics regarding Eskom's financial crisis and the viability of coal-fired power in South Africa, advocating for the accelerated decommissioning of specific power stations and the curtailment of new construction to save costs and improve air quality.
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Document type: Statement
PROVISIONAL APPEAL IN TERMS OF SECTION 62 OF THE LOCAL GOVERNMENT MUNICIPAL SYSTEMS ACT 32 OF 2000
This document is a provisional appeal filed on 13 November 2017 by groundWork, represented by the Centre for Environmental Rights, against the transfer of a provisional atmospheric emission licence (PAEL) for the Khanyisa coal-fired power station. The appellant argues that the transfer from Anglo Operations (Pty) Ltd to ACWA Power Khanyisa Thermal Power Station RF (Pty) Ltd is invalid because the licence does not reflect the project's increased capacity of 600MW, fails to account for cumulative air quality impacts in the Highveld Priority Area, and was processed without required public participation or valid delegation of authority.
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Document type: Statement
BROKEN PROMISES
This October 2017 report by the Centre for Environmental Rights, groundWork, and the Highveld Environmental Justice Network evaluates the failure of the Highveld Priority Area (HPA) to improve air quality in South Africa. Despite the 2007 declaration of the HPA and the 2012 Air Quality Management Plan (AQMP), the report concludes that air quality remains poor and non-compliant with health-based standards, largely due to industrial emissions, inadequate monitoring, and a lack of government capacity and enforcement.
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Document type: Report
UPDATE ON THE PREFERRED BIDDERS UNDER THE FIRST BID WINDOW OF THE COAL BASELOAD IPP PROCUREMENT PROGRAMME AND THE PROPOSED KIPOWER COAL-FIRED POWER STATION
The Centre for Environmental Rights (CER), representing Earthlife Africa Johannesburg and groundWork, submitted a letter to the IPP Office of the Department of Energy on 15 September 2017. The letter provides updates on legal and environmental challenges facing three proposed coal-fired power stations: Thabametsi, Khanyisa, and KiPower. The CER argues that these projects fail to meet the legal qualification criteria for financial close or preferred bidder status due to missing climate change impact assessments (CCIA) and pending disputes over environmental and water licenses.
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Document type: Statement
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) submitted a briefing to the Portfolio Committee on Environmental Affairs on 12 June 2017, detailing the failure of the Highveld Priority Area (HPA) to meet national air quality standards. The CER argues that postponements of minimum emission standards (MES) granted to Eskom and Sasol have hindered progress, and that the national air quality monitoring network is severely dysfunctional.
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Document type: Statement
REQUEST FOR MEETING TO DISCUSS WAY FORWARD ON ESKOM’S NON-COMPLIANCE WITH EMISSION STANDARDS
The Centre for Environmental Rights (CER) requested a meeting with the Department of Environmental Affairs to discuss Eskom's non-compliance with emission standards. Based on a report by Professor Eugene Cairncross analyzing data from April 1, 2015, to March 31, 2016, the CER highlights widespread violations of PM10, NOx, and SO2 limits across multiple power stations and calls for stricter monitoring and reporting guidelines.
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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), representing groundWork and the Highveld Environmental Justice Network (HEJN), submitted preliminary comments on the Department of Environmental Affairs' (DEA) draft mid-term review (MTR) of the Highveld Priority Area (HPA) Air Quality Management Plan (AQMP). The CER argues that the draft review is outdated, lacks a systematic methodology, and fails to provide sufficient evidence to support its conclusions, ultimately concluding that the HPA's goal of achieving compliance with national ambient air quality standards (NAAQS) has not been met.
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Document type: Statement
COMMENTS ON THE DRAFT STRATEGY TO ADDRESS AIR POLLUTION IN DENSE LOW INCOME SETTLEMENTS
The Centre for Environmental Rights (CER), representing several environmental justice organisations, submitted comments on the 2016 Draft Strategy to Address Air Pollution in Dense Low Income Settlements. While welcoming the document, the CER argues that it lacks measurable plans, adequate baseline data, and a strategy for community consultation to effectively address the health impacts of domestic fuel burning in South Africa.
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Document type: Statement
HPA REVIEW QUESTIONNAIRE TO DETERMINE WHETHER AIR QUALITY IN THE NKANGALA DISTRICT MUNICIPALITY HAS IMPROVED SINCE 2007
The Centre for Environmental Rights (CER) issued a questionnaire to the eMalahleni Local Municipality (ELM) on 15 June 2016 to conduct a "mini shadow review" of air quality improvements in the Highveld Priority Area (HPA) since 2007. The briefing seeks to determine if the municipality has the capacity, financial resources, and personnel to implement the HPA Air Quality Management Plan (AQMP) and to assess whether emissions and ambient air quality have actually improved in the Middelburg and eMalahleni areas.
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Document type: Briefing
HPA REVIEW QUESTIONNAIRE TO DETERMINE WHETHER AIR QUALITY IN THE NKANGALA DISTRICT MUNICIPALITY HAS IMPROVED SINCE 2007
The Centre for Environmental Rights (CER) issued a questionnaire to the Nkangala District Municipality (NDM) on 15 June 2016 to conduct a "mini shadow review" of air quality improvements in the Highveld Priority Area (HPA) since 2007. The briefing seeks to determine if the NDM has the capacity, financial resources, and personnel to implement the HPA Air Quality Management Plan (AQMP) and to assess whether industrial emissions and dust have been reduced.
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Document type: Briefing