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This document is a supporting affidavit filed in the High Court of South Africa (Gauteng Division, Pretoria) by Sven Eaton Patrick Peek, a director of the GroundWork Trust. The affidavit serves to confirm and support the submissions made in a founding affidavit deposed to by Mphatheleni Makaulele regarding a legal matter involving several applicants, including GroundWork, and respondents including the Musina Makhado Special Economic Zone (SOC) Ltd and the Limpopo Department of Economic Development, Environment and Tourism.

This responding statement, submitted by groundWork, argues against an appeal by Karpowership SA (PTY) Ltd regarding the Department of Forestry, Fisheries and the Environment's (DFFE) June 23, 2021, decision to refuse Environmental Authorisation (EA) for a gas-to-power project at the Port of Ngqura. groundWork contends that the project is neither necessary nor desirable, citing significant environmental risks, inadequate public participation, and the existence of more sustainable energy alternatives.

This responding statement, submitted by groundWork to the Department of Forestry, Fisheries and the Environment (DFFE), argues for the dismissal of Karpowership SA (PTY) Ltd’s appeal against the refusal of an Environmental Authorisation (EA) for a gas-to-power project in Richards Bay. groundWork contends that the project is neither necessary nor desirable, citing significant environmental risks, inadequate public participation, and the existence of more cost-effective, renewable energy alternatives.

These regulations under the South African Hazardous Substances Act 15 of 1973 establish a strict licensing and monitoring system for Group I hazardous substances. They mandate that only qualified entities (such as manufacturers, importers, and pharmacists) hold licenses, which must be renewed annually. The rules require rigorous record-keeping in a dedicated 'hazardous substances book' for three years, specific labelling including a skull and crossbones symbol, and strict storage requirements to keep chemicals separate from food. It also prohibits sales to minors under 16 without a written order and forbids the reuse of hazardous substance containers for food or cosmetics.

This practice note outlines the legal proceedings in the High Court of South Africa (Gauteng Division, Pretoria) regarding Case No. 51765/2017. The City of Cape Town is seeking a declaratory order stating that a section 34 determination under the Electricity Regulation Act is not necessary to establish a new power plant for the city. The Centre for Environmental Rights (CER) is applying to be admitted as amicus curiae to address issues concerning the transition to renewable energy and the environmental impacts of coal-fired power stations.

This document is an appeal filed on 17 January 2022 by Anchor Energy LNG Pty Ltd and Nseleni Power Corporation Pty Ltd against the Department of Forestry, Fisheries and the Environment's (DFFE) decision to refuse environmental authorisations for the Nseleni Independent Floating Power Plant (NIFPP) and an associated LNG receiving and storage facility at the Port of Richards Bay.

This 2019 Phase 1 Initial Impact Assessment, produced by the Department of Environment Forestry and Fisheries (DEFF) for the South African Presidency's Socio-Economic Impact Assessment System (SEIAS), evaluates the need for regulations to enforce Air Quality Management Plans (AQMPs) in three priority areas. The document identifies a failure to meet National Ambient Air Quality Standards (NAAQS) due to ineffective AQMP implementation and a lack of accountability for non-industrial stakeholders.

This document is a response from Eskom to a request for information by the Centre for Environmental Rights. It reveals that Eskom does not have standalone decommissioning or emission reduction plans for its coal stations, but instead manages these through broader air quality strategies. A 2010 strategy included in the text outlines a prioritised approach to meeting Minimum Emission Standards, highlighting significant constraints such as water scarcity in the Highveld and the high cost of retrofits (estimated at R28 billion CAPEX in 2009 terms), while suggesting 'offset projects' as a cheaper alternative to technical upgrades.

This fact sheet from the Centre for Environmental Rights outlines projected climate impacts across three geographic areas of South Africa—Limpopo/Lephalale, Emalahleni/Mpumalanga (Highveld), and the Western Cape and coastal regions—across three timeframes from 2021 to 2100, corresponding to temperature increases of 2°C+, 3-4°C, and 4°C+.

A letter from the Independent Power Producer (IPP) Office to the Centre for Environmental Rights (CER) providing an update on the Coal Baseload Independent Power Producers Procurement Programme, specifically regarding bid validity extensions for the Thabametsi and Khanyisa projects.

A statement from the South African Department of Environmental Affairs amending the Environmental Authorisation (EA) issued on 25 February 2015 for the IPP Thabametsi Power Station, a 1200MW coal-fired power station near Lephalale, Limpopo Province.

This fact sheet describes the objectives and approach of South Africa's Integrated Resource Plan (IRP) 2025, focusing on balancing energy supply security, cost minimization, and emission reductions.

A fact sheet by the Centre for Environmental Rights explaining the Integrated Resource Plan (IRP) and a September 2020 Ministerial determination to procure 1500MW of new coal-fired electricity from independent power producers in South Africa.

Expert affidavit by Jesse Burton arguing that the proposed Thabametsi coal-fired power station in South Africa is economically unnecessary, would increase greenhouse gas emissions by 136.1Mt CO2eq over 30 years, and would frustrate the country's Paris Agreement commitments. The document advocates for a transition to a least-cost electricity system dominated by wind and solar PV, which is projected to provide 90% of electricity by 2050.

The Centre for Environmental Rights (CER) and the Legal Resources Centre (LRC) provided joint submissions on 18 July 2012 regarding the National Environmental Management Laws Amendment Bill, 2012. The document offers a detailed critique of proposed amendments to the National Environmental Management Act (NEMA), the Biodiversity Act, and the Air Quality Act, focusing on environmental governance, criminal liability, and the rights of traditional communities.

A letter from the South African Department of Mineral Resources (Mpumalanga Region) notifying William Patrick Bower Proprietary Limited that its application for a coal mining right for specific portions of the farms Groenvlei and Lakenvalei has been accepted, subject to the submission of environmental and BEE documentation.

This case study examines the legal dispute in KATZ v BENEPROPS TWO (PTY) LTD 1998 JDR 0052 (O) regarding the validity of a diamond prospecting contract extension and whether the lodging of an internal appeal against a mining permit suspends that permit's operation.

This document is a letter from Eskom to the South African Department of Environmental Affairs (DEA) dated 17 July 2014. It provides additional information to support Eskom's February 2014 application to postpone compliance with Minimum Emission Standards (MES) for the Kendal Power Station.

A letter from the South African Department of Environmental Affairs to Eskom regarding an application for the postponement of compliance time-frames with the National Environmental Management: Air Quality Act 39 of 2004 for the Kendal Power Station.

This document is a Provisional Atmospheric Emission Licence (AEL) and the accompanying decision letter issued by the Mpumalanga Department of Agriculture, Rural Development, Land and Environmental Affairs to Anglo Operations (Pty) Ltd for the Khanyisa Power Plant. The licence authorizes the operation of solid fuel combustion installations for electricity generation, subject to specific emission limits, monitoring requirements, and environmental mitigation measures.