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This document contains the heads of argument filed by Lephalale Coal Mine (Pty) Ltd (LCM) in the High Court of South Africa. LCM responds to a review application by Earthlife Africa seeking to set aside environmental authorisations for a proposed coal mine in Limpopo Province. LCM concedes that its original climate change impact assessment was insufficient and agrees that the related decision should be reviewed and set aside, but opposes all other grounds of review regarding air quality, health impacts, cumulative impacts, and public consultation.

The Life After Coal campaign, comprising the Centre for Environmental Rights (CER), groundWork, and Earthlife Africa Johannesburg, submitted formal objections on 29 January 2020 to Eskom's applications for alternative emission limits at the Medupi and Matimba power stations. The campaign argues that the applications are procedurally and substantively unlawful, violate the South African Constitution and environmental laws, and rely on a flawed air quality modelling approach in a priority area already suffering from poor air quality.

This document is a cover letter from the Centre for Environmental Rights, sent on 30 October 2019 to the Minister of Environment, Forestry and Fisheries, submitting an appeal on behalf of Earthlife Africa and groundWork. The appeal seeks to set aside a provisional atmospheric emission licence (PAEL) issued to Thabametsi Power Company (Pty) Ltd.

The Centre for Environmental Rights (CER), representing several environmental and community organisations, sent a letter to the National Energy Regulator of South Africa (NERSA) on 19 November 2018. The letter demands that NERSA conduct a formal public participation process regarding the draft Integrated Resource Plan for Electricity 2018 (draft IRP 2018), arguing that NERSA is legally required to do so before concurring with the Minister of Energy.

The Centre for Environmental Rights (CER), acting for Earthlife Africa Johannesburg, submitted comments to the Department of Environmental Affairs (DEA) regarding the Final Scope of Work Report (FSR) for the Thabametsi coal-fired power station. The CER argues that the FSR is inadequate, particularly concerning the Climate Change Impact Assessment (CCIA), and requests that the DEA either reject the report or require significant amendments to align it with the South African Constitution and the National Environmental Management Act (NEMA).

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.

Earthlife Africa Johannesburg (ELA) submitted formal objections to the National Energy Regulator of South Africa (NERSA) regarding a license application by Thabametsi Power Company (Pty) Limited to operate a 630MW coal-fired power plant near Lephalale, Limpopo. ELA argues that the project is financially risky, environmentally damaging, and inconsistent with South Africa's international climate commitments under the Paris Agreement.

This document is an annual emissions report for the Matimba Power Station, submitted by Eskom to the Limpopo Department of Economic Development, Environment and Tourism. It covers the reporting period from April 2016 to March 2017, detailing verified emissions of carbon dioxide, particulates, sulfur dioxide, and nitrogen oxides, as well as compliance with atmospheric emission licenses.

This document is an excerpt from Eskom's Air Quality Improvement Plan, detailing the strategy to reduce particulate and gaseous emissions from its power stations. It outlines a phased and prioritised approach to compliance with Minimum Emission Standards (MES), focusing on retrofitting the highest emitting and newest stations first. The plan identifies critical constraints including funding, water availability on the Highveld, and skilled human resources, while proposing air quality offsets in vulnerable communities to mitigate local pollution.

This report examines land-use management in the Lephalale Local Municipality, focusing on the challenges of a municipality that owns almost no land within its urban edge. It details the municipality's strategies for land acquisition, the provision of integrated human settlements, and the incremental introduction of land-use schemes in rural areas under traditional authorities, specifically the Seleka Traditional Authority. The document highlights the influence of major mining and energy companies, the impact of the Spatial Planning and Land Use Management Act (SPLUMA), and the complexities of intergovernmental relations.