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The Life After Coal Campaign urges the South African Minister of Finance to withhold guarantees for the Thabametsi and Khanyisa coal-fired power stations. The campaign argues these projects fail 'value for money' tests, violate the Public Finance Management Act (PFMA), and would cause irreversible harm to the climate and public health. They highlight that the projects are not part of a least-cost electricity plan and would increase greenhouse gas emissions by 205.7Mt CO2eq over 30 years, potentially exposing the National Treasury to liabilities between R25.2 billion and R225.2 billion.

The report analyzes Mpumalanga's spatial status, identifying a resource-rich province dominated by coal mining and agriculture but facing severe environmental degradation and infrastructure backlogs. Key findings highlight that while the province is a national energy hub, it suffers from poor air quality in the Highveld, critical water scarcity, and significant housing shortages. The analysis emphasizes the need for urban restructuring, agrarian transformation in rural areas, and the protection of strategic water source areas and biodiversity corridors against mining encroachment.

The Centre for Environmental Rights (CER), on behalf of Earthlife Africa and groundWork, submitted comments on September 20, 2018, objecting to the Atmospheric Emission Licence (AEL) application for the proposed Thabametsi coal-fired power station. The CER argues that the project should be refused because it is located in an air quality priority area already in non-compliance with National Ambient Air Quality Standards (NAAQS) and is predicted to cause further non-compliance, specifically regarding sulphur dioxide (SO2). The CER claims the Atmospheric Impact Report (AIR) is fatally flawed due to gross miscalculations of emissions, missing modelling data, and a failure to adequately assess cumulative and health impacts.

Dr. Ranajit (Ron) Sahu provides a critique of the revised Atmospheric Impact Report (AIR) for the proposed Thabametsi Power Plant, asserting that the revised document fails to address most technical deficiencies identified in a previous review of the April 2018 AIR.

The document challenges the narrative that South Africa's public sector is bloated, noting that it employs only about 9% of the labour force and 3.1% of the population, which is below middle-income averages. It identifies a critical shortage of frontline workers, with vacancies potentially reaching up to a million, while highlighting a trend of 'skills intensification' where high-paid managerial posts (Grades 11-16) absorb 15% of salary costs despite representing less than 6% of the workforce. The brief proposes setting minimum staffing ratios for doctors, nurses, and teachers, redeploying 25,000 to 50,000 administrative staff to frontline services, and formalising approximately 360,000 stipend workers. It calls for the abandonment of 'blunt tool' fiscal freezes and the implementation of progressive taxation to fund these developmental imperatives.

The Integrated Resource Plan (IRP) 2018 is a strategic update to South Africa's electricity infrastructure development plan, extending the planning horizon to 2050. It evaluates various energy mix scenarios to balance security of supply, cost, and environmental impact, specifically focusing on the transition from coal to renewable energy and gas. The document also includes a Medium-Term System Adequacy Outlook (MTSAO) for 2018-2023 and a specific climate change and water resources assessment for the proposed Thabametsi coal-fired power station.

The document argues that South Africa's informal economy, which employs 4.5 million people, is characterized by low incomes and poor security. It criticizes state-led repression and the narrow focus of micro-enterprise support, proposing instead a transition toward formalization through the implementation of ILO Recommendation 204. Key recommendations include amending the Labour Relations Act and Basic Conditions of Employment Act to recognize own-account workers as workers, enhancing labour inspectorate capacity, and providing basic infrastructure for those working in public spaces. The brief specifically highlights the need for inclusive policies in informal retail and waste recycling, suggesting that corporate responsibility and innovative financing, such as Extended Producer Responsibility levies, be leveraged to support these sectors.

The report examines the 'political-administrative interface' in South Africa, arguing that while political deployment was a post-apartheid imperative for transformation, it has evolved into a system of clientelism and patronage. Through interviews with public servants in local, provincial, and national government, the authors illustrate how political interference—often driven by factionalism within the ANC—leads to institutional instability, the appointment of incompetent officials, and severe psychological trauma for employees. The document concludes by recommending a shift toward professionalisation, including strengthening the oversight powers of the Public Service Commission and limiting the HR authority of political executives to senior-most positions.

The report identifies Strategic Water Source Areas (SWSAs) as critical land areas that provide a disproportionate amount of surface water runoff or groundwater recharge, sustaining over 50% of South Africa's population and 64% of its economy. It establishes a management framework to mitigate impacts from forestry, agriculture, mining, and invasive alien plants, while providing guidelines for government planners to integrate SWSA maps into strategic development frameworks and zoning schemes.

The report examines the negative externalities of coal power in South Africa, focusing on water consumption, pollution, and health impacts. It argues that the current energy planning (Draft IRP) underestimates the true cost of coal by ignoring water-related externalities, such as acid-mine drainage and the high cost of water treatment. The document suggests that internalising these costs would justify a rapid transition to water-efficient renewable energy, which would also create more jobs and reduce the disproportionate burden on marginalised communities.

The report defines and maps 22 national Strategic Water Source Areas for surface water (SWSA-sw) and 37 for groundwater (SWSA-gw) in South Africa, including transboundary areas in Lesotho and Swaziland. It links these areas to major urban centres and agricultural sectors, highlighting that a small percentage of land provides a disproportionate amount of the region's water. The study identifies significant threats from invasive alien plants, mining, and land degradation, and recommends integrating SWSAs into national policy, legislation, and spatial planning to ensure long-term water security.

The Centre for Environmental Rights (CER), representing several environmental justice organisations, submitted provisional comments on June 29, 2018, regarding the Department of Environmental Affairs' (DEA) proposed amendments to the 2012 National Framework for Air Quality Management in South Africa. The CER argues that the public consultation process was inadequate and that the draft Framework fails to address systemic failures in air quality monitoring, enforcement, and the achievement of previous targets.

The Centre for Environmental Rights (CER), acting for groundwork, Earthlife Africa, and Concerned Citizens of Lephalale, submitted comments on 15 June 2018 objecting to the Final Environmental Impact Report (FEIR) and Waste Management Licence (WML) Variation Application for the Flue Gas Desulphurisation (FGD) Retrofit Project at Medupi Power Station. The CER argues that the FEIR is deficient due to missing data, a 'piecemeal' approach to environmental authorisations, and a failure to adequately assess water and waste impacts.

The report evaluates the South African legal framework for wild animal welfare, highlighting a critical divide between biodiversity conservation (managed by the Department of Environmental Affairs) and animal welfare (managed by the Department of Agriculture, Forestry and Fisheries). It finds that the primary welfare statute, the Animals Protection Act of 1962, is outdated and contains loopholes—specifically the use of the term "unnecessary"—that dilute protection. The report identifies significant failures in the permitting system, noting that provincial authorities often ignore national TOPS regulations and omit welfare conditions from permits. It concludes with recommendations for a standardized national electronic permit database, increased enforcement capacity, and the integration of welfare mandates across environmental and agricultural departments.

The Centre for Environmental Rights (CER) argues that the Thabametsi and Khanyisa coal-fired power stations are unnecessary, economically damaging, and environmentally harmful. CER highlights that Thabametsi's climate impact assessment rated its GHG emissions as "Very Large" and that both plants would be located in air quality priority areas. The document asserts that these projects contradict South Africa's international climate commitments and that renewable energy offers a cheaper, cleaner alternative.

The Centre for Environmental Rights (CER), acting for groundWork and Earthlife Africa, submitted comments on April 19, 2018, regarding the Draft Environmental Impact Report (DEIR) and Waste Management Licence (WML) Variation Application for the Flue Gas Desulphurisation (FGD) Retrofit Project at Medupi Power Station. The CER argues that Eskom has adopted a 'piecemeal approach' to the environmental impact assessment (EIA), deferring critical issues such as water security, waste minimisation, and health impacts to separate processes to 'fast track' the project. The submission specifically challenges the rejection of inlet gas cooler technology, which could reduce water consumption by approximately 30%, and criticizes the plan to co-dispose of gypsum and ash, which would destroy the commercial value of the gypsum.

The report examines the Lephalale Local Municipality's struggle to establish local governance and self-sufficiency in the wake of the Medupi coal power station project. It analyzes how the municipality, historically dependent on corporations like Eskom and Exxaro, navigates the complexities of land ownership, basic service infrastructure, and the influence of private capital and party politics to realize its ambition of becoming a post-apartheid city.

The Centre for Environmental Rights (CER), acting for Earthlife Africa NPC and groundWork, submitted comments on 11 April 2018 regarding the draft Scoping Report for the Mokolo and Crocodile River (West) Water Augmentation Project (Phase 2) (MCWAP-2). The CER argues that the project is based on outdated assumptions regarding South Africa's energy needs and fails to adequately assess climate change, water reserves, and indirect environmental and health impacts.

The document requests four primary amendments to the Environmental Authorisation (EA) for the 1200MW Thabametsi Coal-Fired Power Station: extending the EA validity until 25 February 2023, switching the preferred power line to Alternative 2 for technical feasibility with Eskom, listing all affected properties, and incorporating conditions from a March 2016 Minister's Appeal Resolution. Specialist assessments conclude that these changes, particularly the power line shift, do not significantly increase ecological, heritage, or wetland impacts compared to the original plan, though Alternative 2 increases impacts on protected trees and some pan systems. The report argues that the technical necessity of connecting to the national grid outweighs the marginal environmental disadvantages.

The report concludes that the combined operation of the proposed Thabametsi power plant with the existing Matimba and Medupi plants would cause SO2 concentrations to exceed South Africa's health-based National Ambient Air Quality Standards (NAAQS) at several receptor locations. While NOx and PM2.5 emissions from the plants alone might not exceed standards due to stack dilution, the report finds they will likely cause exceedances when added to existing baseline pollution from mobile sources and the Grootegeluk Mine. Additionally, the author argues that PM2.5 emissions from the proposed Thabametsi mine were significantly underestimated in previous reports by at least a factor of five, likely leading to significant impacts on locations to the south-west.