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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
UPDATE ON THE COAL INDEPENDENT POWER PRODUCER (IPP) COAL-FIRED POWER STATIONS – THABAMETSI & KHANYISA
A letter from the Centre for Environmental Rights (CER) to the National Energy Regulator of South Africa (NERSA) providing updates and requesting the status of electricity generation licence applications for the Thabametsi and Khanyisa coal-fired power stations.
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Document type: Statement
THE DEVELOPMENT BANK OF SOUTHERN AFRICA’S ROLE IN THE FINANCING OF THE PROPOSED THABAMETSI COAL-FIRED POWER PLANT
The Centre for Environmental Rights (CER) issued a statement to the Development Bank of Southern Africa (DBSA) expressing alarm over the bank's role in financing the proposed Thabametsi coal-fired power plant. The CER argues that such financing contradicts the DBSA's own sustainability commitments, ignores a landmark court ruling regarding climate change impacts, and exposes the bank to the risk of stranded assets.
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Document type: Statement
BRICS: Stepping into the Breach
This research paper analyzes the internal dynamics and global positioning of the BRICS grouping amidst a shift in US foreign policy. It highlights the economic dominance of China within the group, the tension between the narrative of equality and actual power imbalances, and the group's commitment to maintaining an open global economy and climate agreements like the Paris accord despite internal rivalries.
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Document type: Research paper
COMMENTS BY THE CENTRE FOR ENVIRONMENAL RIGHTS ON THE DRAFT MINE WATER MANAGEMENT POLICY POSITION
The Centre for Environmental Rights (CER) provides critical feedback on the Department of Water and Sanitation's (DWS) draft Mine Water Management Policy Position. The CER argues that the draft understates the crisis of mine water management in South Africa, citing a systemic failure in mine closures and a lack of compliance monitoring and enforcement. The CER recommends that the DWS utilize existing legislative tools—specifically the National Water Act (NWA), the National Environmental Management Act (NEMA), and the Mineral and Petroleum Resources Development Act (MPRDA)—to enforce the 'polluter pays' principle and secure financial provisions for water treatment before granting licenses.
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Document type: Statement
UK trade policy and climate change: Maximising commercial, climate and development outcomes
This research paper outlines a strategy for the United Kingdom to align its post-Brexit trade policy with climate and development goals. It identifies a potential global market of £1.0–1.8 trillion for low-carbon goods and services by 2030 and highlights UK strengths in offshore wind, green finance, and insurance. The authors propose a 'Trade and Climate Checklist' for Free Trade Agreements (FTAs), focusing on 'triple wins' such as tariff elimination for environmental goods and increased market access for professional services, while cautioning against the use of contested carbon border adjustment mechanisms.
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Document type: Research paper
ARE PRIVATE SUSTAINABILITY STANDARDS OBSTACLES TO, OR ENABLERS OF, SME PARTICIPATION IN VALUE CHAINS? INSIGHTS FROM SOUTH AFRICA AND KENYA
This research paper examines how voluntary sustainability standards (VSS) act as both barriers and enablers for small and medium enterprises (SMEs) attempting to enter global value chains (GVCs) coordinated by multinational corporations (MNCs), with a specific focus on South Africa and Kenya as regional economic gateways.
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Document type: Research paper
MANAGING ECONOMIC MIGRATION IN SOUTH AFRICA
This research paper by the South African Institute of International Affairs (SAIIA) analyzes South Africa's immigration regime and its impact on African economic migrants. It examines the tension between the government's desire to attract highly skilled talent and its efforts to deter irregular, semi-skilled migration. The paper evaluates the 2016 Green Paper on International Migration, noting its potential to streamline some processes while criticizing its regressive proposals for asylum seekers. It also compares South African policies with those of the European Union and discusses the role of the Southern African Development Community (SADC) in regional migration governance.
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Document type: Research paper
WRITTEN SUBMISSIONS ON THE STAKEHOLDER BRIEFING DOCUMENT ON THE CLIMATE CHANGE MITIGATION POLICIES AND MEASURES (PAMS) APPROACH AND METHODOLOGY
The Centre for Environmental Rights (CER) submitted a response to the Department of Environmental Affairs regarding the Climate Change Mitigation Policies and Measures (PAMs) methodology. While supporting the study's objectives, CER argues that the proposed scope of greenhouse gases is too narrow, excluding several gases listed in the 2014 Biennial Update Report (HFCs, PFCs, and SF6) as well as critical pollutants like black carbon and HCFCs. CER recommends extending the scope of the analysis to ensure accuracy and reflect national priority air pollutants.
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Document type: Statement
APPELLANTS’ SUBMISSIONS IN THE APPEAL ON 15 TO 17 AUGUST 2017
This document contains the legal and technical submissions made by a coalition of eight appellants (including Earthlife Africa Johannesburg and BirdLife South Africa) on August 14, 2017, appealing an environmental authorisation (EA) granted to Atha-Africa Ventures (Pty) Ltd for the Yzermyn underground coal mine in Mpumalanga, South Africa.
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Document type: Report
CSIR’S COMPREHENSIVE ALTERNATIVE INTEGRATED RESOURCE PLAN (IRP) FOR ELECTRICITY: MISSING COSTS
The Centre for Environmental Rights (CER), writing on behalf of the Life After Coal Campaign, submitted a letter to the Council for Scientific & Industrial Research (CSIR) on 11 August 2017. The letter argues that the CSIR's "comprehensive alternative" Integrated Resource Plan (IRP) for electricity fails to account for critical health, water, climate, and nuclear-related costs, which leads to an underestimation of the true cost of coal and nuclear energy compared to renewable alternatives.
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Document type: Statement
ADDITIONAL WRITTEN COMMENTS ON THE INTEGRATED RESOURCE PLAN (IRP) UPDATE: ASSUMPTIONS, BASE CASE RESULTS AND OBSERVATIONS, REVISION 1 AND ON THE DRAFT INTEGRATED ENERGY PLAN (IEP): MISSING COSTS
The Centre for Environmental Rights (CER), writing on behalf of the Life After Coal Campaign, submitted additional comments to the South African Department of Energy regarding the Integrated Resource Plan (IRP) and Integrated Energy Plan (IEP). The letter argues that current energy modelling fails to account for critical externalities, specifically the health and water costs of coal, the high nitrous oxide emissions associated with circulating fluidised bed combustion technology, and comprehensive nuclear lifecycle costs.
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Document type: Statement
Request to DEA for records relating to buffer zones
The Centre for Environmental Rights (CER) submitted a formal request to the Department of Environmental Affairs (DEA) for records concerning the implementation of buffer zones around national parks and other protected areas in South Africa, specifically referencing the National Environmental Management: Protected Areas Act 57 of 2003 and the National Environmental Management: Biodiversity Act 10 of 2004.
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Document type: Statement
Thabametsi Power Station Limpopo Province Final Climate Change Study and Palaeontological Impact Assessment COMMENTS AND RESPONSES REPORT
This report documents the responses of Thabametsi Power Company to objections raised by Earthlife Africa and Greenpeace Africa regarding the project's climate change and palaeontological impact assessments. Key points of contention include the project's high GHG emission intensity (1.23 tCO2e/MWh), the failure to quantify the social cost of carbon, and the high risk of water scarcity in the Lephalale region of Limpopo Province. The developer maintains that the project is consistent with South African national energy policy (IRP 2010 and 2016) and that its water needs for Phase 1 are secured through existing allocations from the MCWAP-1 scheme.
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Document type: Report
ESKOM INQUIRY REFERENCE BOOK
This briefing booklet details alleged systemic corruption and 'state capture' at Eskom, South Africa's primary power utility, between 2009 and 2017. It highlights how political interference in board appointments—specifically those linked to the Gupta family—led to the repurposing of governance to facilitate fraudulent procurement in coal, nuclear generators, and consulting services. Key examples include the R659 million pre-payment to Tegeta for the purchase of Optimum Coal Holdings, the irregular award of the Koeberg generator tender to Areva, and R500 million in payments to Trillian Capital Partners. The document argues that these actions resulted in billions in irregular expenditure, a qualified audit in 2017, and a severe decline in the utility's financial and operational integrity.
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Document type: Briefing
E-COMMERCE COUNTRY CASE STUDY SOUTH AFRICA
This case study examines the state of e-commerce in South Africa as of 2017, analyzing its scale, regulatory environment, and potential for economic inclusion. It highlights a growing market dominated by a few key players and a legislative framework primarily governed by the Electronic Communications and Transactions Act 2002. The document identifies significant supply-side infrastructure gaps and demand-side trust issues as primary barriers to growth, while suggesting that e-commerce could be a vital tool for the empowerment of women and the poor.
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Document type: Case study
City of Cape Town v The National Energy Regulator of South Africa and the Minister of Energy
The City of Cape Town (CoCT) has initiated legal action against the National Energy Regulator of South Africa (NERSA) and the Minister of Energy regarding the requirement of a Ministerial determination under section 34 of the Electricity Control Act (ECA) for licensing Independent Power Producers (IPPs).
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Document type: Case study
ArcelorMittal South Africa’s Environmental Master Plan
This briefing describes a legal case in which the Centre for Environmental Rights (CER) represented the Vaal Environmental Justice Alliance (VEJA) to compel ArcelorMittal South Africa (AMSA) to disclose an environmental impact study and records regarding the closure and rehabilitation of the Vaal Disposal Site.
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Document type: Briefing
The proposed KiPower IPP
This case study details legal challenges brought by groundWork and the Centre for Environmental Rights (CER) against the environmental and water authorizations granted for the proposed KiPower coal-fired power station in South Africa.
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Document type: Case study
SOCIO-ECONOMIC IMPACT ASSESSMENT SYSTEM (SEIAS) FINAL IMPACT ASSESSMENT TEMPLATE (PHASE 2)
This document is a final impact assessment template for the Socio-Economic Impact Assessment System (SEIAS), specifically detailing the design, intended outcomes, and projected impacts of a proposed carbon tax in South Africa. It outlines a phased approach to internalise the costs of greenhouse gas (GHG) emissions to encourage a transition to a low-carbon economy while mitigating adverse effects on industrial competitiveness and low-income households.
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Document type: Report