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A statement by Dr. A. Gray, an environmental engineer and atmospheric scientist, regarding the necessity of providing full computer modeling files alongside written reports to ensure the transparency and validity of air dispersion modeling assessments.

The report outlines mitigation and management measures for the operational and closure phases of two unlawful activities at the Tormin Mine: the expansion of a processing area and the construction of a process water dam. It identifies low to insignificant environmental impacts and provides a detailed framework for monitoring and rehabilitation to comply with the National Environmental Management Act (NEMA).

The Centre for Environmental Rights (CER) submits that South Africa must urgently transition from coal to renewable energy due to the declining competitiveness of coal, severe health and environmental impacts, and extreme vulnerability to climate change. The CER argues against new coal and nuclear infrastructure, recommends the decommissioning of non-compliant coal plants, and calls for a transformation of Eskom into an organ of state promoting clean energy. It further emphasizes the need for meaningful public consultation in energy planning and warns against the continued operation of high-emission facilities like Sasol's Secunda complex.

The report concludes that Olifants River flows will likely decline substantially due to a combination of projected precipitation decreases and increased evaporation driven by rising temperatures. Using IPCC data and the South African Climate Change Reference Atlas, the author finds that warming is virtually certain, while annual precipitation is very likely to decrease by 5% to 25%. Drawing on analogs from the American Southwest, the analysis argues that even modest precipitation increases would be overwhelmed by temperature-induced evaporation. The document warns that these flow reductions will exacerbate existing water quality issues, such as pollutant concentrations and harmful algal blooms, and advises against the construction of new coal-fired power plants in the region.

The Centre for Environmental Rights (CER) submitted a formal response to the Portfolio Committee on Environmental Affairs regarding the National Environmental Management Laws Amendment Bill [B14-2017], providing a table of proposed amendments and requesting an oral presentation at public hearings.

The Centre for Environmental Rights (CER), acting for groundWork and Earthlife Africa, submitted comments on April 19, 2018, regarding the Draft Environmental Impact Report (DEIR) and Waste Management Licence (WML) Variation Application for the Flue Gas Desulphurisation (FGD) Retrofit Project at Medupi Power Station. The CER argues that Eskom has adopted a 'piecemeal approach' to the environmental impact assessment (EIA), deferring critical issues such as water security, waste minimisation, and health impacts to separate processes to 'fast track' the project. The submission specifically challenges the rejection of inlet gas cooler technology, which could reduce water consumption by approximately 30%, and criticizes the plan to co-dispose of gypsum and ash, which would destroy the commercial value of the gypsum.

The Life After Coal Campaign and Greenpeace Africa have written to South Africa's Minister of Energy to express concerns that the updated Integrated Resource Plan (IRP) for electricity is being fast-tracked without sufficient public consultation. The authors argue that the IRP must be based on the least-cost technology combination, account for external costs to health and climate, and align with South Africa's Nationally Determined Contribution (NDC) under the Paris Agreement. They specifically oppose the continued inclusion of coal and nuclear power, citing the risk of stranded assets and the need for a just transition to renewable energy. The letter warns that failing to provide a transparent, fair process for public comment would make the final IRP vulnerable to legal challenges.

The Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, comprising the Centre for Environmental Rights, groundWork, Earthlife Africa, and Greenpeace Africa, submitted a letter to the Portfolio Committee on Energy on 16 April 2018. The campaign expressed concern that the updated Integrated Resource Plan (IRP) might be published without further public consideration and comment, which they argue would make the plan "vulnerable to legal challenge". They requested that the Committee ask the Department of Energy whether further public consultation will be provided and urged the Department to consider evidence from the Council for Scientific and Industrial Research (CSIR), Meridian Economics, and the Frankfurt Institute, which they state "confirm that new coal-fired electricity is unnecessary and costly".

The Centre for Environmental Rights (CER), acting for Earthlife Africa NPC and groundWork, submitted comments on 11 April 2018 regarding the draft Scoping Report for the Mokolo and Crocodile River (West) Water Augmentation Project (Phase 2) (MCWAP-2). The CER argues that the project is based on outdated assumptions regarding South Africa's energy needs and fails to adequately assess climate change, water reserves, and indirect environmental and health impacts.

The Centre for Environmental Rights (CER) provides written submissions on the March 2018 Final Draft Report of Climate Change Mitigation Policies and Measures (PAMs). The CER supports the examination of policy effectiveness but identifies several gaps, including the need for better alignment between various government climate projects, the exclusion of certain greenhouse gases and externalities in socio-economic analyses, and a lack of rationale for prioritizing coal-to-liquid production through 2050. The CER emphasizes that the report's findings—specifically regarding the electricity sector as the key to decarbonization—should inform the revision of the Integrated Resource Plan for Electricity (IRP 2010).

The Centre for Environmental Rights (CER), representing Earthlife Africa and groundWork, submitted a formal letter to the National Energy Regulator of South Africa (NERSA) on 4 April 2018. The letter follows a public hearing held on 27 March 2018 regarding generation licence applications for the Thabametsi and Khanyisa coal-fired power stations, raising concerns about the hearing process and requesting further information on NERSA's procedural compliance.

The document requests four primary amendments to the Environmental Authorisation (EA) for the 1200MW Thabametsi Coal-Fired Power Station: extending the EA validity until 25 February 2023, switching the preferred power line to Alternative 2 for technical feasibility with Eskom, listing all affected properties, and incorporating conditions from a March 2016 Minister's Appeal Resolution. Specialist assessments conclude that these changes, particularly the power line shift, do not significantly increase ecological, heritage, or wetland impacts compared to the original plan, though Alternative 2 increases impacts on protected trees and some pan systems. The report argues that the technical necessity of connecting to the national grid outweighs the marginal environmental disadvantages.

The Centre for Environmental Rights (CER) and Greenpeace Africa submitted joint comments on the Draft Carbon Tax Bill, 2017, arguing that the proposed tax rate and extensive allowances are insufficient to incentivize a transition to energy efficiency or meaningfully reduce South Africa's greenhouse gas (GHG) emissions.

The report concludes that the combined operation of the proposed Thabametsi power plant with the existing Matimba and Medupi plants would cause SO2 concentrations to exceed South Africa's health-based National Ambient Air Quality Standards (NAAQS) at several receptor locations. While NOx and PM2.5 emissions from the plants alone might not exceed standards due to stack dilution, the report finds they will likely cause exceedances when added to existing baseline pollution from mobile sources and the Grootegeluk Mine. Additionally, the author argues that PM2.5 emissions from the proposed Thabametsi mine were significantly underestimated in previous reports by at least a factor of five, likely leading to significant impacts on locations to the south-west.

The Life After Coal Campaign and Greenpeace Africa urge the South African Minister of Energy to halt the Thabametsi and Khanyisa coal-fired IPP projects. They argue these plants are legally precarious due to pending court challenges over climate and environmental authorisations, and are economically unnecessary given the availability of cheaper renewable energy. The authors highlight severe risks to water security and air quality in the Highveld Priority Area and Waterberg-Bojanala, while warning that the plants could become stranded assets due to greenhouse gas constraints.

The Centre for Environmental Rights (CER) submitted a letter to the National Energy Regulator of South Africa (NERSA) on 6 March 2018, requesting procedural details for public hearings regarding generation licence applications for the proposed Khanyisa and Thabametsi coal-fired power stations.

The Centre for Environmental Rights (CER), representing groundWork, Earthlife Africa Johannesburg, the Highveld Environmental Justice Network, and the Vaal Environmental Justice Alliance, opposes the Department of Environmental Affairs' (DEA) proposal to create an expert panel to address sulphur dioxide (SO2) abatement. The CER contends that Eskom and Sasol, the country's largest polluters, are using the proposal to avoid compliance with minimum emission standards (MES) and to secure 'rolling postponements'. The document argues that the necessary solution—retrofitting plants with flue gas desulphurisation (FGD) technology or decommissioning non-compliant plants—has already been established through a five-year multi-stakeholder process. Furthermore, it highlights that South African SO2 standards are significantly weaker than those in other developing and developed nations, and that the DEA has no legislative authority to weaken the MES based on industry claims of economic infeasibility.

The Centre for Environmental Rights (CER), on behalf of Earthlife Africa Johannesburg and groundWork, submitted supplementary objections on 5 March 2018 against the Water Use Licence Application (IWULA) and Integrated Water and Waste Water Management Plan (IWWMP) for the proposed Thabametsi coal-fired power station. The objections argue that the project is unnecessary due to excess electricity capacity, poses severe risks to the water-stressed Mokolo Catchment, and fails to account for climate change impacts and toxic coal ash disposal risks.

The report concludes that the proposed Thabametsi Power Plant's coal ash dump is unsuitable and its mitigation measures are insufficient. Key concerns include the siting of the dump atop fault zones, which could facilitate rapid contaminant transport and hinder monitoring, and a groundwater monitoring program that omits numerous critical trace elements. The author also notes significant discrepancies in the applicant's estimated coal combustion residue (CCR) production and argues that the proposed liner system may not meet accepted safety standards, increasing the risk of hazardous waste leaking into water resources used by local populations.

The Centre for Environmental Rights (CER), acting on behalf of groundWork (gW), has issued an urgent request to the South African Department of Water and Sanitation for information and reasons regarding a water use licence (WUL) issued for the proposed 600 MW Khanyisa Independent Power Producer (IPP) coal-fired power station.