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This document is a legal submission by groundWork, represented by the Centre for Environmental Rights, appealing to the Minister of Environmental Affairs to extend the deadline for filing an appeal against the environmental authorisation of the ACWA Power Khanyisa Thermal Power Station. The appellant argues that the authorisation is unlawful because it lacked a comprehensive climate change impact assessment, a requirement recently affirmed by the High Court in the Thabametsi judgment.

The Centre for Environmental Rights (CER) submitted objections to the Final Integrated Water Use Licence Application (IWULA) for KiPower's proposed 600 MW coal-fired power station in Delmas, Mpumalanga. The CER and expert reviewers argue the application is fatally flawed, citing incorrect legal classifications of water use, insufficient groundwater baseline data, failure to address public concerns, and a lack of adequate monitoring and mitigation strategies. They recommend the application be rejected.

This joint submission by several environmental organisations and a consultant to the Portfolio Committee on Mineral Resources addresses the Mineral and Petroleum Resources Development Amendment Bill [B15-2013]. The authors focus on the issues of mine closure, rehabilitation, and financial provision, specifically arguing against a proposed 20-year limit on the retention of funds for latent environmental impacts and calling for better alignment between the MPRDA and the National Environmental Management Act (NEMA).

The GroundWork Trust submitted a formal objection to the National Energy Regulator of South Africa (NERSA) regarding an electricity generation permit application by ACWA Power Khanyisa Thermal Power Station (RF) (Pty) Limited. GroundWork argues that the proposed coal-fired power plant is unnecessary, economically unviable, and would cause severe environmental and public health damage in an area already suffering from critical air pollution.

This document is an affidavit submitted by groundWork, a non-profit environmental justice organisation, to the National Energy Regulator of South Africa (NERSA). It presents supplementary objections to the license application by ACWA Power Khanyisa Thermal Power Station (RF) (Pty) Limited to operate the Khanyisa coal-fired power plant. groundWork argues that the project is unnecessary due to excess energy capacity, would violate constitutional rights to a healthy environment, and poses severe risks to the air quality of the Highveld Priority Area and the water resources of the Olifants River catchment.