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CLIMATE CHANGE GOVERNANCE AND THE CLIMATE CHANGE BILL
The Centre for Environmental Rights (CER) submitted a statement to the Portfolio Committee on Environment, Forestry and Fisheries regarding the Climate Change Bill tabled on 18 February 2022. The CER argues that while the Bill is a critical tool for South Africa's climate response, it contains significant gaps in emission targets, enforcement mechanisms, and transparency. The document also critiques South Africa's 2021 Nationally Determined Contribution (NDC), stating it remains insufficient when compared to the 'fair share' of global mitigation effort required to limit warming to 1.5°C or 2°C.
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Document type: Statement
Climate Change Implications for SA’s Youth
This expert report by Nicholas King, commissioned by the Centre for Environmental Rights, analyzes the projected physical, socio-economic, and ecological impacts of climate change on youth and future generations in South Africa from 2021 through 2060 and beyond. It argues that under current 'business as usual' trajectories, large portions of the country may become uninhabitable, leading to systemic collapses in food and water security, infrastructure, and mental wellbeing.
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Document type: Report
OBJECTIONS TO GENERATION LICENCE APPLICATIONS FOR THABAMETSI AND KHANYISA IPP COAL-FIRED POWER STATIONS
The Centre for Environmental Rights (CER) wrote to the National Energy Regulator of South Africa (NERSA) on 17 February 2020, requesting updates on generation licence applications for the Thabametsi and Khanyisa coal-fired Independent Power Producer (IPP) power stations. The CER highlights significant delays since the March 2018 hearings and argues that the applications are now based on outdated information due to legal challenges, lapsed authorisations, and the withdrawal of bank financing.
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Document type: Statement
Energy Security in South Africa: the business case for energy storage
This 2020 industry brief by GreenCape examines the business case for energy storage in South Africa, focusing on the role of hybrid solar PV and battery systems in mitigating the impact of severe load shedding.
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Document type: Briefing
ENVIRONMENTAL COURT CASES ACROSS THE WORLD
This case study describes the first climate change court case in South Africa, where the non-profit Earthlife Africa challenged the environmental authorisation of the Thabametsi coal-fired power station due to the absence of a climate impact assessment.
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Document type: Case study
Comments on the Provisional Atmospheric Emission License (PAEL) Issued to Thabametsi Power Company (Pty) Ltd.
This report by Dr. Ranajit Sahu provides technical comments on the Provisional Atmospheric Emission License (PAEL) issued to Thabametsi Power Company (Pty) Ltd. The author argues that the PAEL permits the use of outdated, inefficient sub-critical Circulating Fluidized Bed (CFB) technology and relies on flawed Atmospheric Impact Reports (AIRs) that underestimate pollution impacts. Sahu contends that the plant will exacerbate existing air quality violations in the Waterberg Bojanala Priority Area and that the license lacks adequate emissions monitoring and control requirements.
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Document type: Report
THE LIFE AFTER COAL CAMPAIGN - CONCERNS AND RISKS RELATING TO THE PROPOSED INDEPENDENT POWER PRODUCER (IPP) COAL-FIRED POWER STATION PROJECTS UNDER BID WINDOW 1 OF THE COAL BASELOAD IPP PROCUREMENT PROGRAMME
A statement from the Life After Coal Campaign to the South African Minister of Finance outlining financial, legal, and environmental risks associated with two proposed coal-fired power stations under the Coal Baseload Independent Power Producer Procurement Programme (CBIPPP).
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Document type: Statement
COMMENTS ON THE REVISED ATMOSPHERIC IMPACT REPORT AND ATMOSPHERIC EMISSION LICENCE APPLICATION FOR THE PROPOSED IPP THABAMETSI COAL-FIRED POWER STATION
The Centre for Environmental Rights (CER), on behalf of Earthlife Africa and groundWork, submitted comments on September 20, 2018, objecting to the Atmospheric Emission Licence (AEL) application for the proposed Thabametsi coal-fired power station. The CER argues that the project should be refused because it is located in an air quality priority area already in non-compliance with National Ambient Air Quality Standards (NAAQS) and is predicted to cause further non-compliance, specifically regarding sulphur dioxide (SO2). The CER claims the Atmospheric Impact Report (AIR) is fatally flawed due to gross miscalculations of emissions, missing modelling data, and a failure to adequately assess cumulative and health impacts.
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Document type: Statement
COMMENTS ON THE CLIMATE CHANGE BILL, 2018
The Centre for Environmental Rights (CER), representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted detailed comments on the Climate Change Bill, 2018. The CER argues that the Bill focuses too heavily on government bureaucracy and fails to address the urgency of the climate crisis or provide sufficient mechanisms for holding emitters accountable. Key recommendations include setting a strict, legally binding emissions trajectory aligned with the Paris Agreement, ensuring full public disclosure of carbon budgets and GHG reports, and establishing independent oversight and appeals bodies.
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Document type: Statement
RELEVANT INFORMATION CONCERNING THE COAL IPPS – A STUDY BY THE ENERGY RESEARCH CENTRE
The Life After Coal Campaign, comprising the Centre for Environmental Rights, groundWork, and Earthlife Africa, submitted a letter to the National Energy Regulator of South Africa (NERSA) on 7 June 2018. The letter urges NERSA to deny generation licenses for the Thabametsi and Khanyisa coal-fired independent power producer (IPP) projects, citing a University of Cape Town Energy Research Centre (ERC) report that describes the projects as economically inefficient and environmentally harmful.
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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
OBJECTIONS TO GENERATION LICENCE APPLICATIONS FOR THABAMETSI AND KHANYISA IPP COAL-FIRED POWER STATIONS
The Centre for Environmental Rights (CER), representing Earthlife Africa and groundWork, submitted a formal letter to the National Energy Regulator of South Africa (NERSA) on 4 April 2018. The letter follows a public hearing held on 27 March 2018 regarding generation licence applications for the Thabametsi and Khanyisa coal-fired power stations, raising concerns about the hearing process and requesting further information on NERSA's procedural compliance.
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Document type: Statement
PUBLIC HEARINGS IN RESPECT OF THE GENERATION LICENCE APPLICATIONS FOR THE PROPOSED KHANYISA AND THABAMETSI INDEPENDENT POWER PRODUCER COAL-FIRED POWER STATIONS
The Centre for Environmental Rights (CER) submitted a letter to the National Energy Regulator of South Africa (NERSA) on 6 March 2018, requesting procedural details for public hearings regarding generation licence applications for the proposed Khanyisa and Thabametsi coal-fired power stations.
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Document type: Statement
SUPPLEMENTARY OBJECTIONS TO THE WATER USE LICENCE APPLICATION AND INTEGRATED WATER AND WASTE WATER MANAGEMENT PLAN FOR THE PROPOSED THABAMETSI INDEPENDENT POWER PRODUCER COAL-FIRED POWER STATION
The Centre for Environmental Rights (CER), on behalf of Earthlife Africa Johannesburg and groundWork, submitted supplementary objections on 5 March 2018 against the Water Use Licence Application (IWULA) and Integrated Water and Waste Water Management Plan (IWWMP) for the proposed Thabametsi coal-fired power station. The objections argue that the project is unnecessary due to excess electricity capacity, poses severe risks to the water-stressed Mokolo Catchment, and fails to account for climate change impacts and toxic coal ash disposal risks.
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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
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
Water: Facts and Futures
WWF South Africa's 2016 report 'Water: Facts and Futures' details the critical state of the country's water security. It highlights that while only 8% of land generates 50% of river flow, these Water Source Areas are under-protected. The report identifies severe threats from invasive alien plants, failing engineered infrastructure (with 37% urban water loss), and widespread pollution from sewage and mining. It calls for a 'Water and Sanitation Revolution' focusing on nature-based solutions, groundwater management, and decentralized service delivery to ensure equitable access to safe water.
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Document type: Report
ESKOM’S APPLICATION FOR EXEMPTION FROM MINIMUM EMISSION STANDARDS AND POSTPONEMENT OF THE MINIMUM EMISSION STANDARDS TIMEFRAMES FOR ESKOM POWER STATIONS COMMENTS ON THE BACKGROUND INFORMATION DOCUMENT
The Centre for Environmental Rights (CER), representing several community groups and NGOs, submitted comments on July 19, 2013, opposing Eskom's applications for exemptions and postponements regarding Minimum Emission Standards (MES). The CER argues that such applications are legally invalid because ambient air quality standards (AAQS) are already exceeded in the priority areas where most Eskom plants are located. The document highlights severe health risks, particularly from SO2 and mercury, and criticizes Eskom for failing to consider renewable energy alternatives or the decommissioning of worst-performing plants.
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Document type: Statement
FOSSILIZED THINKING
This report by the Center for International Environmental Law (CIEL) critiques the World Bank's 3.75 billion dollar loan to Eskom Holding Limited for the Eskom Investment Support Project in South Africa. The authors argue that the Bank failed to comply with its own Operational Policy 10.04 (OP 10.04) by neglecting to fully quantify and incorporate environmental and social externalities—specifically regarding water scarcity, air quality, and transboundary impacts—into the project's Economic Evaluation, thereby overstating the project's net benefits.
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Document type: Report
cer-letter-to-ipp-unit-18-10-16-8b1d0f21e027627a.pdf
The Centre for Environmental Rights (CER), acting for Earthlife Africa Johannesburg (ELA), wrote to the Department of Energy on 18 October 2016 to question the appointment of Thabametsi Power Company (Pty) Limited as a preferred bidder for a coal-fired power station. The CER highlights a pending High Court review application regarding the project's environmental authorisation, specifically the failure to conduct a climate change impact assessment, and requests clarity on whether Thabametsi disclosed this legal challenge to the Department as required by the procurement criteria.
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Document type: Statement