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OBJECTIONS: ARCELORMITTAL SOUTH AFRICA APPLICATION FOR ALTERNATIVE SO2 MINIMUM EMISSION STANDARDS LIMIT AT DIRECT REDUCTION KILNS, ARCELORMITTAL VANDERBIJLPARK WORKS, GAUTENG PROVINCE
The Centre for Environmental Rights, acting for the Vaal Environmental Justice Alliance (VEJA), submitted formal objections to ArcelorMittal South Africa's (AMSA) application for an alternative SO2 emission limit at its Vanderbijlpark Works. The objections argue that granting a limit of 1,500 mg/Nm³—three times the legal standard of 500 mg/Nm³—would violate constitutional rights to a healthy environment, ignore the conversion of SO2 into dangerous particulate matter (PM), and prioritize corporate cost-savings over public health in a known pollution hotspot.
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Document type: Statement
NATIONAL ENVIRONMENTAL CONSULTATIVE ADVISORY FORUM IN TERMS OF SECTION 3A OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998
The Centre for Environmental Rights (CER), representing groundWork, Earthlife Africa, and the Vaal Environmental Justice Alliance (VEJA), issued a statement to the National Environmental Consultative and Advisory (NECA) Forum regarding the consultative process established under section 3A of the National Environmental Management Act (NEMA). The CER outlines legal requirements for compliance with Minimum Emission Standards (MES) and sets minimum conditions for the Forum's operations to ensure transparency and the protection of affected communities' rights.
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Document type: Statement
APPEAL RESPONSE REPORT
This Appeal Response Report, submitted by Eskom Holdings SOC Limited to the Minister of the Department of Forestry, Fisheries and the Environment (DFFE), appeals the National Air Quality Officer's (NAQO) decisions regarding applications for postponements from the Minimum Emission Standards (MES) for various coal-fired power stations.
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Document type: Report
PRIORITY AREAS - MANAGEMENT OF MULTI-STAKEHOLDER REFERENCE GROUP MEETINGS AND IMPLEMENTATION TASK TEAM MEETINGS
A letter from the Centre for Environmental Rights (CER) to Tokiso Dispute Settlement (Pty) Ltd regarding the management of Multi-Stakeholder Reference Group (MSRG) and Implementation Task Team (ITT) meetings for air quality priority areas in South Africa.
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Document type: Statement
WHO’s First Global Conference on Air Pollution and Health, 30 October - 1 November 2018
A letter from the Life After Coal Campaign to the South African Minister of Health inquiring about the Minister's participation in the WHO's First Global Conference on Air Pollution and Health and highlighting the severe health and economic costs of air pollution in South Africa.
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Document type: Statement
GRIEVANCES ABOUT THE PARTICIPATION OF THE CENTRE FOR ENVIRONMENTAL RIGHTS
The Centre for Environmental Rights (CER) issued this formal response on 16 August 2018 to a memorandum of grievances from The Voice Community Representative Council regarding legal challenges against a proposed coal mine by Atha-Africa Ventures (Pty) Ltd. CER clarifies its role as a non-profit law clinic representing eight civil society organisations, denies representing local farmers or specific agencies, and outlines the environmental and socio-economic risks associated with the proposed mine in a protected area.
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Document type: Statement
RESPONSE TO LETTER OF 16 JULY 2018 AND INPUT REGARDING THE JUST ENERGY TRANSITION TO A LOW-CARBON FUTURE FOR THE PEOPLE OF SOUTH AFRICA
The Life After Coal/Impilo Ngaphandle Kwamalahle (LAC) Campaign, comprising the Centre for Environmental Rights, groundWork, and Earthlife Africa, submitted a response to Minister Jeff Radebe on 8 August 2018. The letter argues against the construction of new coal-fired power plants, specifically the Thabametsi and Khanyisa projects, asserting that they are not the least-cost option and would undermine South Africa's climate commitments and public health.
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Document type: Statement
PROVISIONAL SUBMISSIONS REGARDING THE REVIEW OF THE 2012 NATIONAL FRAMEWORK FOR AIR QUALITY MANAGEMENT IN THE REPUBLIC OF SOUTH AFRICA
The Centre for Environmental Rights (CER), representing several environmental justice organisations, submitted provisional comments on June 29, 2018, regarding the Department of Environmental Affairs' (DEA) proposed amendments to the 2012 National Framework for Air Quality Management in South Africa. The CER argues that the public consultation process was inadequate and that the draft Framework fails to address systemic failures in air quality monitoring, enforcement, and the achievement of previous targets.
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Document type: Statement
REPRESENTATIONS ON THE NOTICE OF INTENTION TO AMEND THE LIST OF ACTIVITIES WHICH RESULT IN ATMOSPHERIC EMISISONS WHICH HAVE OR MAY HAVE A SIGNFICANT DETRIMENTAL EFFECT ON THE ENVIRONMENT, INCLUDING HEALTH, SOCIAL CONDITIONS, ECONOMIC CONDITIONS, ECOLOGICAL CONDITIONS OR CULTURAL HERITAGE
The Centre for Environmental Rights, representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted representations on June 25, 2018, regarding proposed amendments to the List of Activities resulting in atmospheric emissions. While supporting the elimination of 'rolling postponements' for minimum emission standards (MES), the submission argues for stricter requirements for once-off suspensions, greater transparency in application documents, and a more robust public participation process.
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Document type: Statement
REPRESENTATIONS ON THE NOTICE OF INTENTION TO AMEND THE LIST OF ACTIVITIES WHICH RESULT IN ATMOSPHERIC EMISISONS WHICH HAVE OR MAY HAVE A SIGNFICANT DETRIMENTAL EFFECT ON THE ENVIRONMENT, INCLUDING HEALTH, SOCIAL CONDITIONS, ECONOMIC CONDITIONS, ECOLOGICAL CONDITIONS OR CULTURAL HERITAGE
The Centre for Environmental Rights, representing the Life After Coal Campaign, submitted representations to the South African Department of Environmental Affairs supporting the removal of 'rolling postponements' for minimum emission standards. The CER argues for stricter health-based emission limits for facilities seeking suspensions, mandatory public disclosure of decommissioning schedules, and a more robust public participation process, while highlighting that current national air quality standards are inadequate compared to WHO guidelines.
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Document type: Statement
RELEVANT INFORMATION ON THE COAL INDEPENDENT POWER PRODUCERS (IPPS)
The Centre for Environmental Rights (CER) submitted a statement to the Portfolio Committee on Environmental Affairs on May 22, 2018, opposing the approval of coal-fired Independent Power Producers (IPPs), specifically Thabametsi and Khanyisa. The CER argues that these projects are unnecessary, economically damaging, and environmentally catastrophic, citing high greenhouse gas emissions, water scarcity, and air pollution in priority areas.
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Document type: Statement
RELEVANT INFORMATION IN RELATION TO THE DRAFT INTEGRATED RESOURCE PLAN FOR ELECTRICITY UPDATE & THE DRAFT INTEGRATED ENERGY PLAN
The Centre for Environmental Rights (CER), representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted a formal statement to the Portfolio Committee on Energy on 29 November 2017. The document outlines critical concerns regarding the lack of transparency, inadequate public consultation, and the omission of key economic and environmental data in the development of South Africa's draft Integrated Resource Plan (IRP) for Electricity Update and the draft Integrated Energy Plan (IEP).
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Document type: Statement
PRELIMINARY SUBMISSIONS REGARDING THE DRAFT REVIEW OF THE NATIONAL FRAMEWORK FOR AIR QUALITY MANAGEMENT 2017
The Centre for Environmental Rights (CER), representing several environmental justice organizations, submitted preliminary comments on the 2017 draft review of South Africa's National Framework for Air Quality Management. The submission criticizes the Department of Environmental Affairs (DEA) for failing to meet previous targets, lacking transparency in progress reviews, and neglecting meaningful public participation in high-pollution priority areas.
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Document type: Statement
South Africa: Toxic air is now legal
A statement by Friends of the Earth International criticizing the South African government's February 2014 decision to grant air quality standard postponements to major industrial entities, including Eskom, Sasol, and Engen, which the organization argues prioritizes corporate profit over public health.
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Document type: Statement
COMMENTS ON THE DEPARTMENT OF ENVIRONMENTAL AFFAIRS’ DRAFT AIR QUALITY OFFSET POLICY
The Centre for Environmental Rights (CER), acting for several environmental justice organisations, submitted comments on the Department of Environmental Affairs' (DEA) Draft Air Quality Offset Policy. The CER and its clients oppose the use of offsets in principle, arguing they serve as a "cheap option to avoid compliance" with emission standards and could undermine the constitutional right to a healthy environment. The submission highlights significant gaps in the draft policy, including a lack of clear criteria for determining offsets, poor institutional capacity for monitoring and enforcement, and failure to address equity and distributional effects.
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Document type: Statement
ESKOM’S APPLICATION FOR EXEMPTION FROM MINIMUM EMISSION STANDARDS AND POSTPONEMENT OF THE MINIMUM EMISSION STANDARDS TIMEFRAMES FOR ESKOM POWER STATIONS
The Centre for Environmental Rights (CER), representing several community and environmental groups, submitted comments on August 23, 2013, regarding uMoya-NILU Consulting's Plan of Study (PoS). The PoS was designed to support Eskom's applications for exemptions and postponements of Minimum Emission Standards (MES) for its power stations. The CER argues that the PoS is too narrow in scope, fails to include critical pollutants like PM2.5, uses inappropriate modelling software for near-field impacts, and lacks a mechanism to verify model outputs against real-world ambient measurements.
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Document type: Statement
SUBMISSIONS REGARDING THE REVIEW OF THE NATIONAL FRAMEWORK FOR AIR QUALITY MANAGEMENT
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.
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Document type: Statement
2014-05-30-fa27-unresolved-matters-for-wg2-b2f71f4b9934e3eb.pdf
This briefing document details the proceedings of a technical working group meeting on April 28, 2009, regarding unresolved air quality emission standards for various industrial categories. It records disputes and agreements between government representatives (DEAT, DEADP), industry bodies (SAISI, RMEF, FAPA, ACMP), and NGOs (LRC, Groundwork) over specific pollutant limits for NOx, SO2, particulate matter (PM), and heavy metals.
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Document type: Briefing
2014-05-30-fa6-proposed-amendment-to-national-framework-7035f381e26f45b0.pdf
The 2012 National Framework for Air Quality Management in the Republic of South Africa is a strategic plan designed to implement the National Environmental Management: Air Quality Act, 2004 (AQA). It establishes a comprehensive governance cycle for air quality management, delineating roles across national, provincial, and municipal governments, and sets norms for ambient air quality standards, emission controls, and information management via the South African Air Quality Information System (SAAQIS).
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Document type: Report
annexure-f_eskom-comments-of-the-draft-emission-standards-to-direct-general-dea-24-august-2009-1-217fae1117217c92.pdf
A 2009 statement from Eskom to the South African Department of Environmental Affairs (DEA) regarding draft minimum emission standards. Eskom expresses support for the standards as a long-term goal but argues that the proposed timeframes and limit values are practically and financially unfeasible for its existing power station fleet due to resource constraints and economic impacts.
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Document type: Statement