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This document contains the heads of argument filed by Lephalale Coal Mine (Pty) Ltd (LCM) in the High Court of South Africa. LCM responds to a review application by Earthlife Africa seeking to set aside environmental authorisations for a proposed coal mine in Limpopo Province. LCM concedes that its original climate change impact assessment was insufficient and agrees that the related decision should be reviewed and set aside, but opposes all other grounds of review regarding air quality, health impacts, cumulative impacts, and public consultation.

The Centre for Environmental Rights (CER), on behalf of Earthlife Africa and groundWork, submitted formal objections on 14 June 2022 to the Integrated Water Use Licence Application (IWULA) for Phase 2A of the Mokolo Crocodile River (West) Water Augmentation Project (MCWAP-2A). The CER argues that the project is an unnecessary inter-basin transfer designed to support coal expansion, which contradicts South Africa's climate commitments and poses severe risks to aquatic ecosystems and local communities.

The Life After Coal campaign, comprising the Centre for Environmental Rights (CER), groundWork (gW), and Earthlife Africa (ELA), submitted formal objections on 28 August 2020 against Eskom's applications for alternative emission limits at the Medupi and Matimba power stations. The campaign argues that these requests are an unlawful attempt to circumvent South Africa's Minimum Emission Standards (MES) and violate constitutional rights to a healthy environment.

The Life After Coal campaign, comprising the Centre for Environmental Rights (CER), groundWork, and Earthlife Africa Johannesburg, submitted formal objections on 29 January 2020 to Eskom's applications for alternative emission limits at the Medupi and Matimba power stations. The campaign argues that the applications are procedurally and substantively unlawful, violate the South African Constitution and environmental laws, and rely on a flawed air quality modelling approach in a priority area already suffering from poor air quality.

This document is a cover letter from the Centre for Environmental Rights, sent on 30 October 2019 to the Minister of Environment, Forestry and Fisheries, submitting an appeal on behalf of Earthlife Africa and groundWork. The appeal seeks to set aside a provisional atmospheric emission licence (PAEL) issued to Thabametsi Power Company (Pty) Ltd.

This document is a formal appeal submitted by the Centre for Environmental Rights on behalf of Earthlife Africa and groundWork to the Minister of Environmental Affairs. The appeal seeks to set aside an Environmental Authorisation granted on 15 March 2019 to the Department of Water and Sanitation for Phase 2A of the Mokolo and Crocodile River (West) Augmentation Project (MCWAP-2A). The appellants argue that the project is unnecessary, environmentally damaging, and based on outdated energy demand assumptions.

The Centre for Environmental Rights (CER), representing several environmental and community organisations, sent a letter to the National Energy Regulator of South Africa (NERSA) on 19 November 2018. The letter demands that NERSA conduct a formal public participation process regarding the draft Integrated Resource Plan for Electricity 2018 (draft IRP 2018), arguing that NERSA is legally required to do so before concurring with the Minister of Energy.

An appeal by Earthlife Africa Johannesburg and groundWork to set aside the environmental authorisation for the 660 MW Namane coal-fired power station in Limpopo, South Africa. The appellants argue the decision is unlawful due to failures to assess climate change impacts, air quality risks, and water scarcity in the Waterberg region, while ignoring renewable energy alternatives and violating national and international environmental commitments.

The Life After Coal campaign opposes Eskom's application to postpone sulphur dioxide emission standards at the Medupi and Matimba power stations, citing a history of non-compliance, failure to install required abatement technology, and a lack of comprehensive health risk assessments for affected communities in the Waterberg District Municipality.

This case study by the Public Affairs Research Institute (PARI) examines the institutional collapse of the Mogalakwena Local Municipality in South Africa. It argues that the municipality has entered a state of 'perpetual instability' driven by cyclical factionalism within the African National Congress (ANC) at local, regional, and provincial levels. The report details how political battles over the appointment of the Municipal Manager (MM) led to administrative rupture, the use of 'lawfare' to target rivals, and a total shutdown of services in 2014, illustrating a broader trend of institutional fragility within the South African state.

The Centre for Environmental Rights (CER), acting for Earthlife Africa Johannesburg, submitted comments to the Department of Environmental Affairs (DEA) regarding the Final Scope of Work Report (FSR) for the Thabametsi coal-fired power station. The CER argues that the FSR is inadequate, particularly concerning the Climate Change Impact Assessment (CCIA), and requests that the DEA either reject the report or require significant amendments to align it with the South African Constitution and the National Environmental Management Act (NEMA).

This document is an appeal submitted by Earthlife Africa Johannesburg on 11 May 2015 to the Minister of Environmental Affairs. The appeal challenges the environmental authorisation granted on 25 February 2015 to Newshelf 1282 (Pty) Limited for the construction of the 1200 megawatt (MW) coal-fired Thabametsi power station near Lephalale in the Limpopo Province. The appellant argues that the decision was unlawful, failed to consider critical air quality and water scarcity issues, ignored climate change obligations, and violated the Promotion of Administrative Justice Act (PAJA).

The Centre for Environmental Rights (CER), representing groundWork, the South Durban Community Environmental Alliance (SDCEA), and the Vaal Environmental Justice Alliance (VEJA), submitted comments on August 22, 2012, regarding the review of the National Framework for Air Quality Management. The submission criticizes the lack of a systematic review of the 2007 Framework, the absence of a current State of the Air Report, and significant gaps in air quality monitoring and public access to information. The CER advocates for more stringent emission standards, mandatory reporting for data holders, and a more inclusive, transparent review process.

The document is a formal declaration by the Minister of Water and Environmental Affairs designating the Waterberg National Priority Area under the National Environmental Management: Air Quality Act, 2004, due to concerns over ambient air quality and trans-boundary pollution.

The document is an appeal decision by the Minister of Environmental Affairs of the Republic of South Africa regarding an amendment to the Environmental Authorisation (EA) for the Thabametsi Power Station. The project involves the establishment of a 1200MW coal-fired power station and associated infrastructure near Lephalale in the Limpopo Province. After considering an appeal lodged by Earthlife Africa Johannesburg (via the Centre for Environmental Rights), the Minister dismissed the appeal but amended several conditions of the EA to address typographical errors, clarity on water monitoring, and heritage resource requirements.

This document is an Integrated Water and Waste Management Plan (IWWMP) from July 2016 for the proposed coal-fired IPP Thabametsi Power Plant project in the Lephalale Local Municipality, Limpopo Province. It details the project's technical specifications, water requirements, and waste management infrastructure.

The Department of Economic Development, Environment and Tourism (LEDET) of the Limpopo Province refused an Environmental Authorisation (EA) for the proposed Meletse Iron Ore Mining project. The project, proposed by Aquila Steel (S Africa) (Pty) Ltd, would have involved an open pit mining operation and associated infrastructure on the farms Donkerpoort 448 KQ and Randstephne 455 KQ. The refusal was based on the determination that ecological, visual, and traffic impacts could not be mitigated and that the project conflicted with required land use for the site.

The Minister of Environmental Affairs of South Africa issued a decision on 30 January 2018 to confirm the Environmental Authorisation (EA) for the construction of the 1200MW Thabametsi coal-fired power station. This decision followed a North Gauteng High Court order remitting the matter for reconsideration specifically regarding climate change and paleontological impact assessments.

The Minister of Forestry, Fisheries and the Environment of South Africa dismissed eight appeals against the decision to grant an Environmental Authorisation (EA) to the Department of Water and Sanitation for Phase 2 of the Mokolo and Crocodile River (West) Water Augmentation Project (MCWAP-2A Project). The decision confirms the project's need to provide water infrastructure for power stations and urban use in the Waterberg region.

Earthlife Africa Johannesburg (ELA) submitted formal objections to the National Energy Regulator of South Africa (NERSA) regarding a license application by Thabametsi Power Company (Pty) Limited to operate a 630MW coal-fired power plant near Lephalale, Limpopo. ELA argues that the project is financially risky, environmentally damaging, and inconsistent with South Africa's international climate commitments under the Paris Agreement.