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ClientEarth argues that Ofgem's current statutory objectives are outdated and prioritize competition over decarbonisation, hindering long-term climate investments. The submission proposes narrowing Ofgem's principal objective to focus on security of supply and greenhouse gas reduction, introducing sector-specific carbon budgets, and requiring the Department for Business, Energy and Industrial Strategy (BEIS) to issue periodic Strategy and Policy Statements. Additionally, ClientEarth highlights a failure to regulate and verify non-carbon dioxide emissions, specifically methane and sulphur hexafluoride (SF6), and advocates for a consumption-based emissions accounting approach to include extraterritorial emissions from imported energy.

This document is a technical map dated 27 June 2018 showing a mined-out area above decant level in KwaZulu-Natal, South Africa, specifically near Utrecht. It uses a coal floor model based on exploration borehole data to delineate mine boundaries and decant areas.

This responding statement, submitted by the Centre for Environmental Rights on behalf of eight appellants, challenges the Department of Mineral Resources' (DMR) approval of the Environmental Management Programme (EMPR) for Atha-Africa Ventures (Pty) Ltd's proposed Yzermyn mine. The appellants argue that the approved EMPR authorizes an environmentally destructive discard dump, ignores extensive government conservation policies for the area, and contains woefully inadequate financial provisions for rehabilitation.

The document details a dispute over coal prospecting rights granted by the Department of Minerals (DMR) to Samancor Chrome Limited, later ceded to Commissiekraal Coal (Pty) Ltd and Bright Coal (Pty) Ltd, on the Farm Commissiekraal in KwaZulu-Natal. The case is highlighted because the prospecting occurs at the headwaters of the Pongola river system, a highly sensitive area. While the landowner, Nico Lens, supported the activity, downstream users and environmental groups—including the Greater Pongola River Catchment Protection Association (GPRCPA), WWF, and the Impala Water Users Association—opposed it, citing a lack of consultation. The GPRCPA only discovered the operations by chance through a contractor. The case raises concerns regarding the DMR's interpretation of the Mineral and Petroleum Resources Development Act (MPRDA) concerning ecological degradation and the transparency of the transfer of prospecting rights. An administrative appeal against the prospecting right was lodged on 15 February 2011.

The document details the environmental and social costs of coal-power generation in South Africa, specifically focusing on the Kusile power station. It highlights that water-related externalities for Kusile range from R0.95 to R1.86 per kWh, driven largely by water use in generation and mining. The text argues that the Draft Integrated Resource Plan (IRP) 2016 misrepresents the total cost of coal by ignoring these externalities. It further notes that coal mining and power generation consume 3% and 2% of South Africa's water respectively, with severe regional impacts in the Upper Olifants. The report emphasizes the long-term costs of acid-mine drainage and the disproportionate health and water-security burdens placed on poor communities, concluding that a decarbonised energy future would require four times less water by 2050 and create more jobs than the coal-reliant base case.