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The review concludes that the specialist reports for the Yzermyn underground coal mine are insufficient, failing to identify all environmental impacts and the interconnection between hydrogeology, hydrology, and wetlands. Consequently, the issued IWUL lacks sufficient conditions to mitigate impacts to an acceptable standard. Key failures include a low-confidence groundwater model (Class 1) that cannot quantify seasonal variations, a lack of field-based wetland delineation for the underground mining area, and the absence of a post-closure water treatment cost analysis. The report highlights that mine dewatering will likely cause significant drawdown in shallow and deep aquifers, potentially drying up high-value wetlands and springs, while post-closure acid mine drainage (AMD) and contaminant plumes remain unsimulated and unquantified.

The review identifies critical gaps in the hydrogeological and wetland assessments for the Yzermyn Underground Coal Mine, specifically regarding the impact of mine dewatering on sensitive ecosystems and the lack of post-closure water treatment planning.

The peer review concludes that the Greenhouse Gas Assessment (GGA) and Climate Resilience Assessment (CRA) are comprehensive and follow international best practices, though it identifies gaps in the quantification of the Social Cost of Carbon and questions the overall project impact rating. While the project's GHG emissions are rated as 'VERY LARGE' and water scarcity risks as 'HIGH', the reviewer notes that the project's justification relies on existing South African energy policy, which remains a point of contention.

The 'First Draft Carbon Tax Bill 2015: Response Document' is a December 2017 report by the Centre for Environmental Rights (representing the National Treasury's responses) that details public comments and government feedback on the design of South Africa's carbon tax. It addresses key policy issues including revenue recycling, tax-free allowances for trade-exposed sectors, the treatment of the electricity and aviation sectors, and the alignment of the tax with South Africa's Nationally Determined Contribution (NDC) under the Paris Agreement.

The Centre for Environmental Rights (CER), representing various non-governmental and community organisations, submitted recommendations to the Department of Environmental Affairs (DEA) on November 30, 2017, to strengthen the proposed amendments to the National Dust Control Regulations 2013 under the National Environmental Management: Air Quality Act, 2004 (AQA).

The document assesses the impact of underground mine workings on the shallow weathered and deep fractured Karoo aquifers within the Mabola Protected Environment. It simulates groundwater drawdown, noting that while the deep fractured aquifer's zone of impact extends approximately 2 km downstream or North of the mine, significant impacts (drawdowns above 20m) are limited to the area immediately above the workings. The report suggests that the 15-year mine life may be shorter than the time required to reach a steady-state cone of dewatering. Groundwater-dependent ecosystems and springs within the site boundaries may be negatively impacted by the dewatering of the shallow aquifer, whereas those in the deeper fractured aquifer are considered unlikely to be affected due to the limited connection between the two aquifer systems.

The Centre for Environmental Rights, on behalf of the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, urges the Portfolio Committee on Energy to compel the Department of Energy to release key technical data and conduct fair public consultations before finalising the IRP Update and IEP. The submission highlights the Department's failure to respond to PAIA requests for modelling assumptions and tariff implications. It further argues that the current planning ignores the health and water costs of coal, the emissions of nitrous oxide from CFB technology, and the financial viability of new coal and nuclear plants. Citing studies by Meridian Economics and the Frankfurt Institute, the document asserts that accelerating the decommissioning of older coal stations and prioritising wind and solar PV is the most cost-effective path for South Africa's energy future.

A coalition of environmental and social justice organisations has formally objected to a planned 'energy indaba' scheduled for December 2017, arguing that it does not constitute meaningful public participation for the draft Integrated Energy Plan (IEP) and Integrated Resource Plan (IRP) Update. The organisations claim the event's short notice and single venue in Gauteng exclude many affected parties. Furthermore, they allege that the Department of Energy has failed to provide critical technical reports and modelling data requested under the Promotion of Access to Information Act (PAIA), which are essential for stakeholders to provide informed input on South Africa's energy future.

The Centre for Environmental Rights (CER) presents findings from a Meridian Economics study arguing that Eskom can save up to R17 billion and improve public health without compromising energy security by decommissioning the Hendrina, Grootvlei, and Komati power stations and curtailing the completion of Kusile units 5 and 6. The letter highlights that new coal and nuclear plants are no longer cost-competitive compared to solar PV and wind, and notes that Eskom's failure to comply with minimum emission standards (MES) should necessitate decommissioning.

The Centre for Environmental Rights (CER), representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted additional comments to the South African Department of Energy regarding the Integrated Resource Plan (IRP) and Integrated Energy Plan (IEP). The CER argues that these plans must incorporate missing cost calculations for coal and nuclear energy, as well as findings from recent studies suggesting that accelerating the decommissioning of coal plants and cancelling new coal and nuclear capacity is the most cost-effective path for Eskom and the national grid.

The report argues that Eskom is facing a liquidity and financial crisis driven by stagnant electricity demand and the high costs of its coal-fired power construction programme. Through system-level modelling and station-specific analysis, the study finds that the levelised costs of operating older coal stations (Arnot, Camden, Grootvlei, Hendrina, and Komati) exceed their system alternative value, meaning they can be replaced by cheaper alternatives without compromising security of supply. Specifically, decommissioning Grootvlei, Hendrina, and Komati early could save Eskom R12.5bn in present value terms. Additionally, the report finds that cancelling Kusile units 5 and 6 is economically viable if capital cost savings exceed a threshold of approximately R4.7bn. The authors conclude that South Africa no longer requires new nuclear, coal, or gas procurement, as solar PV and wind have become the most competitive new-build options.

The Centre for Environmental Rights, acting on behalf of groundWork, has filed a provisional appeal under Section 62 of the Local Government Municipal Systems Act 32 of 2000 regarding the transfer of a provisional atmospheric emission licence (PAEL) for the proposed Khanyisa coal-fired power station.

This document is a provisional appeal filed on 13 November 2017 by groundWork, represented by the Centre for Environmental Rights, against the transfer of a provisional atmospheric emission licence (PAEL) for the Khanyisa coal-fired power station. The appellant argues that the transfer from Anglo Operations (Pty) Ltd to ACWA Power Khanyisa Thermal Power Station RF (Pty) Ltd is invalid because the licence does not reflect the project's increased capacity of 600MW, fails to account for cumulative air quality impacts in the Highveld Priority Area, and was processed without required public participation or valid delegation of authority.

Civil society organisations, including Greenpeace Africa and the Life After Coal Campaign, have requested a meeting with South Africa's Minister of Energy to address the integrity of the Integrated Energy Plan (IEP) and Integrated Resource Plan (IRP). The signatories argue that the current process has "substantial flaws" and advocate for a just transition from coal to publicly-owned renewable energy and energy efficiency. They propose eleven principles for the IRP, emphasizing least-cost technology combinations, the inclusion of external costs to health and climate, and alignment with the Paris Agreement and South Africa's Nationally Determined Contribution (NDC). The letter specifically seeks clarity on timelines, public participation, the status of energy determinations for coal, nuclear, gas, and renewables, and the delay in Independent Power Producer agreements.

The Thabametsi Power Company (Pty) Ltd is applying for a Water Use License for a 630 MW coal-fired power plant near Lephalale, Limpopo. The project will use dry-cooled Circulating Fluidised Bed technology to achieve zero liquid effluent discharge. Water will be sourced via a permanent transfer of 720,000 m3/annum from Exxaro Coal (Pty) Ltd's existing allocation. The application covers several water uses under the National Water Act, including taking and storing water, altering watercourses, and disposing of waste. While the project is expected to create 14,348 jobs and support local industry, it faces challenges regarding water scarcity in the Mokolo Dam catchment and potential groundwater pollution from ash dumps and coal stockpiles. Mitigation measures include HDPE liners for pollution control dams and a comprehensive groundwater monitoring program.

The report concludes that the Highveld Priority Area (HPA) has failed to improve air quality over the decade since its 2007 declaration. Despite the 2012 air quality management plan, ambient air quality remains out of compliance with health-based standards, largely due to industrial non-compliance and government failure in monitoring and enforcement. The authors highlight a deterioration in the monitoring network, inadequate dust control for mining, and a lack of resources and skilled staff within local municipalities. The report specifically criticizes the National Air Quality Officer for granting compliance postponements to major polluters Eskom and Sasol, arguing that this has hindered pollution reduction and violated the constitutional rights of residents.

The report concludes that the Highveld Priority Area (HPA) has failed to improve air quality over a decade, with ambient air remaining in widespread non-compliance with health-based national ambient air quality standards (NAAQS). This failure is attributed to inadequate government capacity, a lack of financial and human resources at the municipal level, and the failure of major industrial emitters, specifically Eskom and Sasol, to reduce emissions. The report highlights a deteriorating monitoring network, ineffective dust control regulations, and a lack of progress in addressing indoor air pollution in low-income settlements. It argues that the granting of postponements from minimum emission standards (MES) to major polluters has further hindered progress, violating the constitutional rights of residents to an environment not harmful to their health.

The Centre for Environmental Rights (CER) criticises the draft 2017 National Framework for Air Quality Management for failing to review progress against previous targets and for inadequate public participation. The submissions highlight persistent non-compliance with national ambient air quality standards in priority areas, severe delays in the implementation of the South African Air Quality Information System (SAAQIS), and deficiencies in greenhouse gas reporting. CER demands more transparent, facility-level GHG reporting, stricter air quality standards aligned with WHO guidelines, and the urgent appointment of air quality officers and inspectors to ensure enforcement of the Air Quality Act.

The Centre for Environmental Rights (CER) informs the South African Department of Energy that the Thabametsi and Khanyisa coal-fired power stations, both preferred bidders under the Coal Baseload IPP Procurement Programme (CBIPPPP), and the proposed KiPower station do not meet the legal qualification criteria for financial close. The CER highlights that a North Gauteng High Court ruling established that a full climate change impact assessment (CCIA) is a necessary part of the environmental impact assessment (EIA) for coal-fired plants. Thabametsi's CCIA indicated the plant would be one of the highest greenhouse gas emitters in the country and faces high water availability risks. Khanyisa and KiPower have failed to conduct CCIAs. The letter also notes that these projects are located in the water-stressed Olifants River Catchment and the Highveld Priority Area, where air quality is out of compliance with health standards. The CER requests clarification on whether the financial close deadline has been suspended pending the updated Integrated Resource Plan (IRP) and Integrated Energy Plan (IEP).

A letter from the Centre for Environmental Rights (CER) to the National Energy Regulator of South Africa (NERSA) providing updates and requesting the status of electricity generation licence applications for the Thabametsi and Khanyisa coal-fired power stations.