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Land and the Just Transition: A guide for local government
This guide, produced by PARI, IIED, and SALGA, provides a framework for South African local governments to integrate land governance into the just transition. It argues that land is a strategic public resource essential for climate resilience and social justice, rather than merely a financial asset. The document outlines how municipalities can use spatial planning, inclusive governance, and tenure protection to balance the land-intensive needs of renewable energy and climate adaptation with the need to redress historical spatial inequalities from the apartheid era.
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Document type: Guide
‘Unjust’ Transition for Youth in South Africa
This policy brief examines the 'unjust' nature of the energy transition for youth in South Africa's Steve Tshwete Local Municipality (STLM). It argues that while the transition from fossil fuels to renewable energy is necessary, young people are being marginalised through exclusionary land allocation policies, a lack of sustainable employment following the closure of coal-fired power stations, and the limited scope of renewable energy projects that fail to provide meaningful skills or long-term job security.
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Document type: Policy brief
UPDATED EXPERT ANALYSIS OF THE AIR QUALITY IMPACTS AND HEALTH EFFECTS DUE TO THE EMISSIONS FROM ESKOM’S KENDAL POWER STATION
The Centre for Environmental Rights submitted a letter to the South African Minister of Environment, Forestry and Fisheries reporting that Eskom's Kendal power station had 2,851 particulate matter emission exceedances between April 2016 and March 2020. The letter alleges that Eskom may be improperly reporting these contraventions as 'Grace' or 'Section 30' exceedances to avoid penalties and highlights that emissions from 13 of Eskom's coal-fired plants were linked to 320 premature deaths in 2018.
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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 THABAMETSI & KHANYISA COAL-FIRED POWER STATION
A letter from the Centre for Environmental Rights to the IPP Office of the Department of Energy requesting updates on the commercial and financial close deadlines for the Thabametsi and Khanyisa coal-fired power station projects, while asserting that neither project is currently capable of reaching such close due to outstanding licenses and pending litigation.
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Document type: Statement
Mpumalanga Spatial Development Framework
The Mpumalanga Spatial Development Framework (PSDF) is a strategic report designed to guide the province's spatial transformation, aiming to reverse apartheid-era spatial imbalances and promote sustainable, inclusive economic growth. It proposes a polycentric growth management model based on a hierarchy of growth centres and corridors to integrate urban and rural areas.
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Document type: Report
REGULATIONS FOR IMPLEMENTING AND ENFORCING THE HIGHVELD PRIORITY AREA AIR QUALITY MANAGEMENT PLAN (2012)
This document consists of a series of letters and a report summary from the Centre for Environmental Rights (CER) addressed to the South African Department of Environmental Affairs (DEA). The CER, representing various environmental groups, argues that the Highveld Priority Area (HPA) has failed to improve air quality since its 2007 declaration. The CER demands the urgent implementation of regulations to enforce the 2012 Air Quality Management Plan (AQMP), the elimination of 'rolling postponements' for emission standards granted to major polluters like Eskom and Sasol, and a formal response to the 'Broken Promises' report regarding the ongoing violation of constitutional rights to a healthy environment.
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Document type: Statement
UPDATE ON THE PREFERRED BIDDERS UNDER THE FIRST BID WINDOW OF THE COAL BASELOAD IPP PROCUREMENT PROGRAMME
The Centre for Environmental Rights (CER), representing Earthlife Africa and groundWork, issued a statement to the IPP Office of the Department of Energy on 16 November 2018. The letter seeks clarity on the status of the Thabametsi and Khanyisa coal-fired power stations, the preferred bidders under the Coal Baseload Independent Power Producer Procurement Programme (CBIPPPP), specifically regarding their commercial and financial close deadlines and the signing of power purchase agreements (PPAs).
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Document type: Statement
Spatial Challenges and Opportunities Report
The Spatial Challenges and Opportunities Report (2018) provides a comprehensive biophysical, socio-economic, and built environment analysis of Mpumalanga Province to inform its Provincial Spatial Development Framework (PSDF). The report identifies a resource-based economy heavily dependent on coal mining and electricity generation, while highlighting significant spatial fragmentation, infrastructure backlogs, and environmental threats to biodiversity and water sources.
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Document type: Report
OUTCOMES OF THE MEETING WITH NGOs ON THE IMPLEMENTATION OF THE HIGHVELD PRIORITY AREA HELD ON 12 DECEMBER 2017
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.
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Document type: Statement
PROVISIONAL APPEAL IN TERMS OF SECTION 62 OF THE LOCAL GOVERNMENT MUNICIPAL SYSTEMS ACT 32 OF 2000
This document is a provisional appeal filed on 13 November 2017 by groundWork, represented by the Centre for Environmental Rights, against the transfer of a provisional atmospheric emission licence (PAEL) for the Khanyisa coal-fired power station. The appellant argues that the transfer from Anglo Operations (Pty) Ltd to ACWA Power Khanyisa Thermal Power Station RF (Pty) Ltd is invalid because the licence does not reflect the project's increased capacity of 600MW, fails to account for cumulative air quality impacts in the Highveld Priority Area, and was processed without required public participation or valid delegation of authority.
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Document type: Statement
BROKEN PROMISES
This October 2017 report by the Centre for Environmental Rights, groundWork, and the Highveld Environmental Justice Network evaluates the failure of the Highveld Priority Area (HPA) to improve air quality in South Africa. Despite the 2007 declaration of the HPA and the 2012 Air Quality Management Plan (AQMP), the report concludes that air quality remains poor and non-compliant with health-based standards, largely due to industrial emissions, inadequate monitoring, and a lack of government capacity and enforcement.
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Document type: Report
PRELIMINARY COMMENTS ON THE DRAFT MID-TERM REVIEW OF THE HIGHVELD PRIORITY AREA AIR QUALITY MANAGEMENT PLAN
The Centre for Environmental Rights (CER), representing groundWork and the Highveld Environmental Justice Network (HEJN), submitted preliminary comments on the Department of Environmental Affairs' (DEA) draft mid-term review (MTR) of the Highveld Priority Area (HPA) Air Quality Management Plan (AQMP). The CER argues that the draft review is outdated, lacks a systematic methodology, and fails to provide sufficient evidence to support its conclusions, ultimately concluding that the HPA's goal of achieving compliance with national ambient air quality standards (NAAQS) has not been met.
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Document type: Statement
APPEAL IN TERMS OF SECTION 62 OF THE LOCAL GOVERNMENT: MUNICIPAL SYSTEMS ACT, 2000 OF ESKOM’S HENDRINA POWER STATION ATMOSPHERIC EMISSION LICENCE 17/4/AEL/MP312/11/16 ISSUED ON 31 MARCH 2015
This document is a formal appeal submitted by the Centre for Environmental Rights (CER) on behalf of groundWork, Earthlife Africa Johannesburg, and the Highveld Environmental Justice Network. The appeal challenges the variation of the Atmospheric Emission Licence (AEL) for Eskom's Hendrina Power Station, issued by the Nkangala District Municipality on 31 March 2015. The appellants argue that the AEL improperly incorporates postponements of Minimum Emission Standards (MES) granted by the National Air Quality Officer, thereby permitting pollution levels that exceed national standards in a declared priority area with already compromised air quality.
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Document type: Report
DRAFT STRATEGY TO ADDRESS AIR POLLUTION IN DENSE LOW-INCOME SETTLEMENTS
The Centre for Environmental Rights (CER) issued a statement to the Director-General of the Department of Environmental Affairs calling for the urgent public release of the 'Strategy to Address Air Pollution in Dense Low-Income Settlements'. The CER argues that the delay in publishing this strategy, which was a deliverable as far back as 2010, hinders the state's ability to protect the constitutional rights of residents in low-income settlements who suffer from severe health impacts due to industrial emissions and domestic fuel burning.
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Document type: Statement
ADDITIONAL SUBMISSIONS REGARDING THE VARIATION OF THE ATMOSPHERIC EMISSION LICENCE FOR ESKOM’S KRIEL POWER STATION
The Centre for Environmental Rights (CER), representing several community and environmental groups, submitted a response to the Nkangala District Municipality opposing Eskom's application to vary the atmospheric emission licence for the Kriel Power Station. The CER argues that the variation would permit increased emissions of particulate matter (PM10) and mercury, leading to significant public health risks and economic costs, while challenging Eskom's dispersion modelling and cost calculations for abatement technology.
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Document type: Statement
OBJECTIONS TO THE VARIATION OF THE ATMOSPHERIC EMISSION LICENCE FOR ESKOM’S KRIEL POWER STATION
The Centre for Environmental Rights (CER), representing various community and environmental groups, submitted formal objections to Eskom's application to vary the Atmospheric Emission Licence (AEL) for the Kriel Power Station. The CER argues that the requested increase in particulate matter (PM) emissions would exacerbate poor air quality in the Highveld Priority Area, cause significant health impacts, and result from Eskom's own poor planning rather than a genuine emergency.
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Document type: Statement
4-progress-report-fb269491caeec439.pdf
This progress report from SRK Consulting, dated October 6, 2016, outlines the initial activities and status of a project involving Eskom, focusing on stakeholder engagement, baseline assessments, and alignment with national development goals.
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Document type: Report
doc-1.1-g-brd-ses-eskom-env-perf-comp-and-risks-29-may-17-69117be3be1f45a5.pdf
This briefing document, submitted to Eskom's Board Social, Ethics and Sustainability Committee on 29 May 2017, provides an update on the organization's environmental performance, compliance status, and risk management for the 2016/17 financial year. It details emissions and water usage metrics, legal contraventions, the progress of air quality improvement and offset projects, and the implementation of biodiversity and bird mitigation strategies.
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Document type: Briefing
duvha-ael-variation-request_final_jan14-d3a833e92a946554.pdf
Eskom has submitted an emergency request to the Nkangala District Municipality to vary the Atmospheric Emission Licence (AEL) for Duvha Power Station. The request seeks a 'grace period' allowing specific units to exceed particulate emission limits during maintenance and emergency repairs, specifically to address a leaking sulphur tank that poses a safety risk and threatens power supply stability.
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Document type: Statement
duvha-annual-emissions-report-2015-2016-e549bc1c813daaf8.pdf
This annual emissions report for the Duvha Power Station covers the 2015/16 financial year (01 April 2015 to 31 March 2016), detailing verified particulate emissions and calculated gas emissions as required by the station's Atmospheric Emission License.
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Document type: Report