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1,323 documents from Centre for Environmental Rights
OBJECTIONS TO THE INTEGRATED WATER USE LICENCE APPLICATION FOR PROPOSED IPP THABAMETSI POWER STATION
The Centre for Environmental Rights, acting for Earthlife Africa Johannesburg, submitted formal objections on 20 January 2017 to the Integrated Water Use Licence Application (IWULA) for the proposed 1200MW coal-fired Thabametsi power station near Lephalale, Limpopo. The submission argues that the application is fatally flawed due to outdated data, failure to account for climate change, risks to groundwater and wetlands, and a lack of guaranteed water availability for the project's 40-year lifespan.
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Document type: Statement
OBJECTIONS TO THE INTEGRATED WATER USE LICENCE APPLICATION FOR PROPOSED IPP THABAMETSI POWER STATION
The Centre for Environmental Rights, acting for Earthlife Africa Johannesburg, submitted formal objections on 20 January 2017 to the Integrated Water Use Licence Application (IWULA) for the proposed Thabametsi power station, a 1200MW coal-fired project near Lephalale, Limpopo. The objections argue that the application is legally flawed, relies on outdated data, fails to secure a sustainable water supply for the project's 40-year lifespan, and poses significant risks to groundwater and wetlands.
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Document type: Statement
Coal-Fired Power Station and Associated Infrastructure - IPP Waterberg (Thabametsi) Power Station near Lephalale: Climate Change Study and Palaeontological Impact Assessment: Summary Report
The report assesses the environmental impacts of the proposed Thabametsi coal-fired power station, focusing on greenhouse gas (GHG) emissions, climate resilience, and palaeontological risks. It finds that while the project will have a 'High (Negative)' significance rating due to 'Very Large' GHG emissions, it aligns with South Africa's energy policy and is more efficient than the country's oldest coal plants. Climate risks include water shortages and high temperatures, while palaeontological risks are rated as low to medium depending on the geological formation. The report concludes there are no environmental fatal flaws, provided mitigation measures are implemented.
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Document type: Executive summary
Marine Spatial Planning Workshop Report and Outcomes
The report details a workshop focused on integrating civil society into South Africa's Marine Spatial Planning (MSP) process. It identifies critical gaps in the Draft MSP Bill and Framework, such as the lack of an ecosystem-based approach and insufficient public participation. Key recommendations include establishing a civil society institutional structure (like a stakeholder forum or Community of Practice), aligning academic research with national MSP milestones, and developing an information-sharing portal to improve transparency and data accessibility.
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Document type: Report
Request to DEA for correspondence between the Atha-Africa Ventures (Pty) Ltd relating to the planned Yzermyn in the Mabola Protected Environment
The Centre for Environmental Rights (CER) submitted a request to the Department of Environmental Affairs (DEA) on 7 December 2016 for records concerning the proposed Yzermyn underground coal mine in the Mabola Protected Environment.
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Document type: Statement
IWULA, IWUL and Specialist Investigation Review of the Yzermyn Colliery Mpumalanga
The review finds that the specialist studies for the Yzermyn underground coal mine are materially incomplete, particularly regarding hydrogeology, wetlands, and hydrology. The groundwater model is classified as low confidence (Class 1), failing to account for seasonal variations or the specific characteristics of dolerite sills, dykes, and faults. This leads to an underestimation of impacts on groundwater-dependent ecosystems, including the potential drying up of springs and wetlands. Hydrological assessments are based on outdated layouts and fail to adhere to General Notice 704 regarding flood line Exclusion Zones. Consequently, the report argues that the issued IWUL lacks sufficient conditions to mitigate environmental risks to an acceptable standard.
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Document type: Report
SUBMISSIONS ON FINAL SCOPE OF WORK REPORT FOR THABAMETSI IPP COAL-FIRED POWER STATION DEA REF 14/12/16/3/3/3/40
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).
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Document type: Statement
FOLLOW UP TO REQUEST FOR REVIEW AND STRENGTHENING OF THE NATIONAL DUST CONTROL REGULATIONS
The Centre for Environmental Rights (CER) is calling for a review of South Africa's National Dust Control Regulations, arguing that current monitoring methods are inadequate and that the government is incorrectly treating fugitive dust as a 'nuisance' rather than a health risk. CER specifically highlights the danger of toxic substances like arsenic and uranium in gold mine residues in Gauteng and opposes a proposal to double the allowable 30-day average dust limit from 600mg/m2 to 1200mg/m2. The letter also demands that the scope of regulated activities be expanded to explicitly include gold mine tailings re-mining operations.
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Document type: Statement
Request to DEA for the application by Atha-Africa Ventures to mine in the Mabola Protected Environment
The Centre for Environmental Rights (CER) submitted a request to the Department of Environmental Affairs (DEA) on 20 October 2016 for records concerning Atha-Africa Ventures' application to mine commercially in the Mabola Protected Environment.
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Document type: Statement
APPELLANTS’ STATEMENT OF GROUNDS OF APPEAL IN TERMS OF SECTION 96(1)(a) OF THE MINERAL AND PETROLEUM RESOURCES DEVELOPMENT ACT, 2002, AND REGULATION 74 OF THE MINERAL AND PETROLEUM RESOURCES DEVELOPMENT REGULATIONS, 2004
This document is a statement of grounds of appeal filed on 13 October 2016 by eight environmental and community organisations against the approval of the Environmental Management Programme (EMPR) for the Yzermyn underground coal mine. The appellants argue that the approval, granted by the Mpumalanga Regional Manager of the Department of Mineral Resources (DMR) on 28 June 2016, ignored critical biodiversity risks, failed to provide adequate mitigation for water resource degradation, and disregarded the socio-economic vulnerability of local rural communities.
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Document type: Statement
COMMENTS BY THE CENTRE FOR ENVIRONMENTAL RIGHTS ON THE PROPOSED AMENDMENTS TO THE FINANCIAL PROVISIONING REGULATIONS, 2015
The Centre for Environmental Rights (CER) submitted comments to the Department of Environmental Affairs on October 7, 2016, regarding proposed amendments to the Financial Provisioning Regulations, 2015. The CER argues that several proposed deletions of appendices and clauses would create legal uncertainty, reduce transparency, and weaken the state's ability to ensure that mining rehabilitation funds are available and used correctly.
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Document type: Statement
REQUEST TO INCLUDE CERTAIN RECORDS IN, AND TO REMOVE CERTAIN LIMITATIONS FROM, THE DEPARTMENT OF MINERAL RESOURCES’ DECLARATION IN TERMS OF SECTION 15 OF THE PROMOTION OF ACCESS TO INFORMATION ACT, 2000
The document is a formal request to the Department of Mineral Resources (DMR) to increase transparency by expanding the list of records automatically available to the public under section 15 of the Promotion of Access to Information Act (PAIA). The signatories argue that the DMR's 2014 declaration improperly limits access to specific categories of persons and excludes critical documents such as mining rights, environmental authorisations, and compliance reports, which are essential for affected communities to hold mining companies accountable.
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Document type: Statement
REQUEST FOR THE DEPARTMENT OF HEALTH TO PARTICIPATE AS A STAKEHOLDER IN THE HIGHVELD PRIORITY AREA MULTI-STAKEHOLDER REFERENCE GROUP MEETINGS
The Centre for Environmental Rights (CER) and groundWork are urging the South African Department of Health to join the Highveld Priority Area (HPA) Multi-Stakeholder Reference Group (MSRG). They argue that the Department of Health's involvement is critical given the severe health burden caused by air pollution in the HPA, particularly from Eskom's coal-fired power stations. The document cites data suggesting thousands of premature deaths and significant IQ loss due to mercury emissions, as well as the economic costs of these health impacts, to justify the need for health officials to collaborate on air quality solutions.
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Document type: Statement
CHAMBER OF MINES RESPONSE TO CERs REPORT: ZERO HOUR: POOR GOVERNANCE OF MINING AND THE VIOLATION OF ENVIRONMENTAL RIGHTS IN MPUMALANGA
The Centre for Environmental Rights (CER) defends its 'Zero Hour' report against criticisms from the Chamber of Mines, asserting that the report's findings on environmental violations in Mpumalanga are based on extensive evidence. The CER rejects the Chamber's claim that the Department of Mineral Resources (DMR) has a proven track record of regulation, instead citing a 'consistent failure' in compliance monitoring and enforcement. The CER calls for increased transparency, better protection of strategic water source areas, and improved DMR capacity to prevent further environmental degradation.
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Document type: Statement
OPEN LETTER TO THE MINISTERS OF PUBLIC ENTERPRISES, ENERGY, ENVIRONMENTAL AFFAIRS AND HEALTH
The document argues that Eskom is obstructing South Africa's transition to renewable energy and violating constitutional rights through the continued operation of polluting coal-fired power stations. The signatories call for the removal of barriers to small-scale renewable energy, the decommissioning of ageing coal plants, and greater transparency regarding emission compliance plans.
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Document type: Statement
South Africa’s 2nd Biennial Update Report 2016
South Africa's 2nd Biennial Update Report (2016) provides a comprehensive assessment of the country's greenhouse gas (GHG) emissions from 2000 to 2012, highlighting the energy sector as the primary contributor. It outlines national mitigation strategies, including the introduction of a carbon tax and carbon budgets, and details the financial resources mobilized from bilateral and multilateral sources. The report also describes the development of a national monitoring, reporting, and verification (MRV) system and the National Greenhouse Gas Inventory System (NGHGIS) to improve data accuracy and transparency.
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Document type: Report
COMMENTS ON THE DRAFT STRATEGY TO ADDRESS AIR POLLUTION IN DENSE LOW INCOME SETTLEMENTS
The Centre for Environmental Rights (CER), representing several environmental justice organisations, submitted comments on the 2016 Draft Strategy to Address Air Pollution in Dense Low Income Settlements. While welcoming the document, the CER argues that it lacks measurable plans, adequate baseline data, and a strategy for community consultation to effectively address the health impacts of domestic fuel burning in South Africa.
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Document type: Statement
WRITTEN SUBMISSIONS TO THE SOUTH AFRICAN HUMAN RIGHTS COMMISSION FOR THE NATIONAL INVESTIGATIVE HEARING ON THE UNDERLYING SOCIO-ECONOMIC CHALLENGES IN MINING-AFFECTED COMMUNITIES IN SOUTH AFRICA
The document argues that poor environmental governance by the Department of Mineral Resources (DMR) and the Department of Water and Sanitation (DWS) leads to systemic violations of environmental rights in South Africa's mining sector. It highlights severe impacts on water resources, including acid mine drainage and the depletion of aquifers, and notes the destruction of strategic water source areas (SWSAs). The CER identifies critical failures in the Environmental Impact Assessment (EIA) process, citing insufficient timeframes for public participation and a lack of independence among practitioners. It recommends transferring environmental regulation of mines from the DMR to environmental authorities, implementing free prior and informed consent (FPIC) for communities, and establishing 'no-go' areas for mining in ecologically sensitive zones.
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Document type: Statement
APPELLANTS’ STATEMENT OF GROUNDS OF APPEAL IN TERMS OF SECTION 43(2) OF NEMA AND REGULATION 61 OF THE ENVIRONMENTAL IMPACT ASSESSMENT REGULATIONS, 2010
A statement of grounds of appeal filed by eight environmental and community organisations against an environmental authorisation granted on 7 June 2016 to Atha Africa Ventures (Pty) Ltd for the Yzermyn underground coal mine near Wakkerstroom, Mpumalanga. The appellants argue that the authorisation is based on a fundamentally flawed Environmental Impact Assessment Report (EIAR) that ignores critical biodiversity risks, fails to address socio-economic impacts on vulnerable communities, and was granted by an incorrect competent authority.
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Document type: Statement
Review of Environmental Impact Assessment Report & Environmental Management Programme, and Environmental Authorisation, for Yzermyn underground coal project
The review concludes that the Yzermyn underground coal project's EIAR and EMPr are of poor quality, failing to address critical concerns from the Department of Environmental Affairs (DEA), Department of Water Affairs (DWA), and Department of Mineral Resources (DMR). The author argues that the project poses high risks to 'irreplaceable' biodiversity and water resources, specifically regarding acid mine drainage and the drawdown of wetlands. The review asserts that the competent authority ignored these risks and the NEMA principles when granting environmental authorisation, focusing only on surface footprint rather than landscape-scale impacts.
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Document type: Report