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Dr. Ranajit (Ron) Sahu provides a critique of the revised Atmospheric Impact Report (AIR) for the proposed Thabametsi Power Plant, asserting that the revised document fails to address most technical deficiencies identified in a previous review of the April 2018 AIR.

The Life After Coal Campaign, comprising the Centre for Environmental Rights, groundWork, and Earthlife Africa, urged the South African National Department of Health to participate in the WHO's First Global Conference on Air Pollution and Health (30 October - 1 November 2018). The letter asserts that air quality in South Africa frequently exceeds ambient air quality standards (AAQS), particularly in the Highveld, Mpumalanga, and Waterberg-Bojanala priority areas, and that the Vaal Triangle Airshed and Highveld Priority Areas remain at dangerous exposure levels despite being declared priority areas over a decade ago. The campaign notes that South African AAQS are significantly weaker than the WHO's 2005 guidelines. Citing a 2016 report by Dr Mike Holland, the letter states that PM2.5 emissions from Eskom's coal-fired power stations alone cause 2,239 deaths per year, including 1,110 from ischaemic heart disease and 157 from lung cancer, with total associated economic costs exceeding USD2 billion annually. The document identifies Eskom and Sasol as the country's largest emitters of regulated criteria pollutants.

The CER argues that the DBSA's potential financing of the Thabametsi and Khanyisa coal-fired power plants contradicts its mandate for sustainable development and violates constitutional environmental rights. The CER highlights that these projects face significant legal challenges regarding licenses and would result in greenhouse gas emission intensities nearly 60% higher than Eskom's Medupi and Kusile plants. Furthermore, the CER cites evidence that South Africa has surplus base supply capacity and that these plants would increase costs by R19.68 billion compared to a least-cost energy system.

The Centre for Environmental Rights (CER) and a coalition of eight civil society organisations defend their legal opposition to a proposed coal mine by Atha-Africa Ventures (Pty) Ltd. CER argues that the mine would threaten a Strategic Water Source Area and a protected environment, while asserting that coal mining in Mpumalanga has historically failed to alleviate poverty or provide sustainable local employment. The document clarifies that CER does not represent local farmers or WWF-SA and disputes claims that its actions are 'anti-development', citing the constitutional right to a healthy environment.

The Life After Coal Campaign (LAC) argues that new coal-fired power plants in South Africa are irrational, costly, and contrary to international climate obligations. The campaign highlights the severe water externalities of coal, the health risks associated with the proposed Khanyisa power station, and the financial risks of stranded assets as global investment shifts away from thermal coal. LAC advocates for a just transition that prioritizes renewable energy, protects workers' livelihoods, and ensures Eskom's active role in a sustainable energy system.

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.

The Centre for Environmental Rights (CER), on behalf of the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, has written to Eskom to challenge the procurement of two coal-fired independent power producers (IPPs): Thabametsi and Khanyisa. The CER argues that these projects are not 'value for money' as they would increase system costs by 19.6 billion Rand, raise greenhouse gas emissions, and risk becoming stranded assets. The letter highlights that the projects lack necessary licenses and are subject to pending High Court reviews. It requests detailed information on the status of the PPAs, the 'value for money' assessment, and compliance with the Public Finance Management Act (PFMA) and New Generation Regulations.

The Centre for Environmental Rights (CER), representing the Life After Coal Campaign, is challenging the progression of the Thabametsi and Khanyisa coal-fired power stations. The CER argues that these projects fail the 'value for money' test, would increase greenhouse gas emissions, and are unable to reach commercial close due to missing licenses and pending High Court reviews. The letter requests detailed information on the status of the procurement process and the specific regulatory approvals required before PPAs can be signed.

The Integrated Resource Plan (IRP) 2018 is a strategic update to South Africa's electricity infrastructure development plan, extending the planning horizon to 2050. It evaluates various energy mix scenarios to balance security of supply, cost, and environmental impact, specifically focusing on the transition from coal to renewable energy and gas. The document also includes a Medium-Term System Adequacy Outlook (MTSAO) for 2018-2023 and a specific climate change and water resources assessment for the proposed Thabametsi coal-fired power station.

The Centre for Environmental Rights (CER) submitted a response on 16 July 2018 to the Dr Pixley Ka Isaka Seme Local Municipality, reiterating objections to a land-use change application for a proposed mine. The CER argues that the subject property is a high-priority conservation area and that the Municipality has the legal authority and obligation under the Spatial Planning and Land Use Management Act (SPLUMA) to consider environmental and water impacts, despite claims to the contrary by the applicant's agent.

The report identifies Strategic Water Source Areas (SWSAs) as critical land areas that provide a disproportionate amount of surface water runoff or groundwater recharge, sustaining over 50% of South Africa's population and 64% of its economy. It establishes a management framework to mitigate impacts from forestry, agriculture, mining, and invasive alien plants, while providing guidelines for government planners to integrate SWSA maps into strategic development frameworks and zoning schemes.

The report examines the negative externalities of coal power in South Africa, focusing on water consumption, pollution, and health impacts. It argues that the current energy planning (Draft IRP) underestimates the true cost of coal by ignoring water-related externalities, such as acid-mine drainage and the high cost of water treatment. The document suggests that internalising these costs would justify a rapid transition to water-efficient renewable energy, which would also create more jobs and reduce the disproportionate burden on marginalised communities.

The report defines and maps 22 national Strategic Water Source Areas for surface water (SWSA-sw) and 37 for groundwater (SWSA-gw) in South Africa, including transboundary areas in Lesotho and Swaziland. It links these areas to major urban centres and agricultural sectors, highlighting that a small percentage of land provides a disproportionate amount of the region's water. The study identifies significant threats from invasive alien plants, mining, and land degradation, and recommends integrating SWSAs into national policy, legislation, and spatial planning to ensure long-term water security.

The Centre for Environmental Rights (CER), representing several environmental justice organisations, submitted provisional comments on June 29, 2018, regarding the Department of Environmental Affairs' (DEA) proposed amendments to the 2012 National Framework for Air Quality Management in South Africa. The CER argues that the public consultation process was inadequate and that the draft Framework fails to address systemic failures in air quality monitoring, enforcement, and the achievement of previous targets.

The South African Water Caucus (SAWC) identifies a state of "institutional crisis" within the Department of Water and Sanitation (DWS), citing severe financial mismanagement, human resource challenges, and a failure to maintain water infrastructure. The document highlights the critical risk posed by 212 wastewater treatment plants and the lack of water quality reporting since 2013. SAWC urges the Ministry to prioritize the establishment of nine Catchment Management Agencies (CMAs), protect 22 strategic water source areas, and address the R60 billion estimated cost for treating acid-mine drainage from approximately 5,906 derelict and ownerless mines. The letter also calls for water allocation reform to address inequities where industrial agriculture receives 60% of water but Black emerging farmers receive only 3% of that allocation.

The Centre for Environmental Rights, representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted representations on June 25, 2018, regarding proposed amendments to the List of Activities resulting in atmospheric emissions. While supporting the elimination of 'rolling postponements' for minimum emission standards (MES), the submission argues for stricter requirements for once-off suspensions, greater transparency in application documents, and a more robust public participation process.

The Centre for Environmental Rights (CER) sent a formal request to the South African Department of Environmental Affairs (DEA) on 25 June 2018, demanding access to pollution prevention plans and greenhouse gas (GHG) reporting records. The CER disputes the DEA's claims of confidentiality regarding emissions data from major companies and calls for transparency to ensure the effectiveness of the national mitigation system.

The Centre for Environmental Rights (CER) has declined an invitation to debate the merits of legal challenges against a proposed coal mine by Atha-Africa Ventures Pty Ltd in a forum proposed by The Voice Community Representative Council. CER and its coalition of eight non-profit organisations oppose the mine because it is located within a declared protected area and a strategic water source area, which they argue would threaten South Africa's water security with non-mitigatable damage. While acknowledging the need for job creation, CER highlights the historical devastation of health and livelihoods caused by coal mining in the Mpumalanga Highveld. Instead of the proposed forum, CER invited The Voice to a meeting in Emalahleni, Mpumalanga, to view the impacts of existing mining and hear presentations on their opposition.

The Centre for Environmental Rights, on behalf of the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, supports the elimination of 'rolling postponements' for emission standards but argues that the draft legislation lacks sufficient safeguards. The submission recommends that postponement applications be contingent on ambient air quality compliance, require full public disclosure of decommissioning schedules, and mandate stricter emission standards for facilities seeking once-off suspensions, particularly in air quality priority areas.

The Centre for Environmental Rights (CER), representing various community-based and non-governmental organisations, submits that the 2018 Draft Amendments to the National Dust Control Regulations fail to address critical weaknesses in dust emission management and monitoring in South Africa. The CER argues that the reliance on the ASTM D1739 test method is inappropriate as it masks short-term high-emission events and does not protect human health. They advocate for the inclusion of 'best practicable environmental measures' (BPEM), mandatory PM10 monitoring, and specific geochemical and radionuclide analysis for dust from tailings storage facilities. The submission also emphasizes the need for stronger local government enforcement, particularly in priority areas like the Highveld, and calls for the regulations to take effect immediately rather than on 1 November 2019.