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This document is a December 2012 submission by Natref to the Department of Environmental Affairs (DEA) regarding the draft Notice of Minimum Emission Standards (MES) under the National Environmental Management: Air Quality Act, 2004. Natref, South Africa's only inland oil refinery, argues that the proposed point-source emission limits for sulphur dioxide (SO2), particulate matter (PM), and nitrogen oxides (NOx) are technically and economically unfeasible due to its unique inland location, fuel oil requirements, and space constraints. The company advocates for a "bubble" approach to emissions management and requests differentiated limits based on fuel type to maintain business sustainability and ensure the success of the Clean Fuels II project.

This document is a submission from Sasol to the South African Department of Environmental Affairs (DEA) detailing the company's objections to the requirement that existing industrial plants meet 'new plant standards' for emissions by April 1, 2020. Sasol argues that retrofitting old facilities is often technically impossible due to space and configuration constraints, economically unviable, and potentially counterproductive to other environmental goals, such as carbon footprint reduction and water conservation.