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The Centre for Environmental Rights (CER), representing various community-based and non-governmental organisations, submits that the 2018 Draft Amendments to the National Dust Control Regulations fail to address critical weaknesses in dust emission management and monitoring in South Africa. The CER argues that the reliance on the ASTM D1739 test method is inappropriate as it masks short-term high-emission events and does not protect human health. They advocate for the inclusion of 'best practicable environmental measures' (BPEM), mandatory PM10 monitoring, and specific geochemical and radionuclide analysis for dust from tailings storage facilities. The submission also emphasizes the need for stronger local government enforcement, particularly in priority areas like the Highveld, and calls for the regulations to take effect immediately rather than on 1 November 2019.

The Centre for Environmental Rights (CER), acting for several NGOs, sent a letter to the Department of Environmental Affairs (DEA) on 19 January 2018. The letter outlines the outcomes and commitments from a meeting held on 12 December 2017 regarding the implementation of the Highveld Priority Area (HPA), specifically addressing the DEA's delayed response to the 'Broken Promises Report' and the roles of NGOs in community representation.

The Vaal Triangle Priority Area AQMP Implementation Regulations, 2009, establish the legal framework for implementing and enforcing the Vaal Triangle Air-shed Priority Area Air Quality Management Plan (VTAQMP). The regulations mandate that identified stakeholders submit and periodically review emission reduction strategies to ensure ambient air quality objectives are met.