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A letter from the Centre for Environmental Rights to the South African Department of Environmental Affairs requesting urgent improvements to the management of Multi-Stakeholder Reference Group (MSRG) and Implementation Task Team (ITT) meetings for designated air quality priority areas.

The Centre for Environmental Rights (CER), representing several environmental justice organisations, submitted comments on the draft National Atmospheric Emissions Inventory System (NAEIS) Reporting Regulations. The CER argues that the draft regulations contain overly broad confidentiality restrictions that hinder public access to emissions data, contradicting international best practices and South African constitutional and statutory principles.

The authors contend that seabed mining poses multi-pronged threats to the equilibrium of the marine realm, specifically risking the benthic communities that underpin fisheries and the phytoplankton responsible for CO2 absorption. They argue that the pursuit of minerals should not come at the expense of renewable food resources or existing economic activities. The text highlights skepticism toward foreign mining companies in Namibia and South Africa, noting that such companies often seek to operate in these regions after being denied permits in countries like Australia and New Zealand. The authors call for rigorous, open quantification of mining scopes and the application of the precautionary principle to avoid enormous environmental and socio-economic implications.

The Centre for Environmental Rights, Centre for Applied Legal Studies, and the Open Democracy Advice Centre argue that the 2014 Mining Lekgotla and similar industry forums exclude critical stakeholders and lack transparency. They highlight the difficulty of accessing essential environmental and mining documents and call for more inclusive governance to ensure natural resources benefit all South Africans.

The Centre for Environmental Rights (CER) submitted a letter to the Department of Environmental Affairs on 24 June 2014, arguing that Eskom failed to conduct necessary health impact assessments for its applications to postpone Minimum Emission Standards (MES). The CER highlights expert estimates of significant premature deaths and economic costs resulting from Eskom's emissions and notes that Eskom previously withheld its own internal health risk reports from the public.

The Centre for Environmental Rights (CER) is campaigning for increased reporting of environmental crimes through the National Environmental Crimes and Incidents Hotline (0800 205 005). The CER argues that the South African government, specifically the Treasury, underinvests in compliance monitoring and enforcement, which violates the constitutional right to a healthy environment. Because the hotline is the only mechanism where reports are centrally collated and published annually by the Department of Environmental Affairs (DEA), the CER asserts that higher reporting numbers are necessary to provide an accurate picture of the scale of violations and to pressure the state to allocate more funding and personnel to enforcement.

The Centre for Environmental Rights has called for a criminal investigation into water contamination in Bloemhof, Northwest, following an outbreak of diarrhoeal disease that caused hundreds of illnesses and the deaths of three infants under two years of age. The request targets potential culpable homicide and violations of the National Water Act, Water Services Act, and National Environmental Management Act, specifically citing the alleged negligence of the Lekwa Teemane Municipal Manager and a contractor regarding sewage spillage.

The Pixley Ka Seme District Spatial Development Framework (2013-2018) provides a strategic spatial plan for a region in the Northern Cape, South Africa, characterized by vast landscapes and significant socio-economic challenges. Key priorities include leveraging the SKA project in Carnarvon, developing a renewable energy hub (particularly solar), and optimizing transport corridors (N1, N8, N10, N12) and the Orange River corridor. The plan emphasizes sustainable water management in a water-scarce region, the promotion of Karoo-based agro-tourism, and the integration of local municipalities to foster economic growth and poverty eradication.

The Centre for Environmental Rights submitted additional comments to the Department of Environmental Affairs regarding the declaration of greenhouse gases as priority pollutants, specifically requesting clearer distinctions in the classification of land use and land use change.

The Centre for Environmental Rights, representing several environmental justice organisations and community groups, submitted comments to the Department of Environmental Affairs regarding the declaration of greenhouse gases (GHGs) as priority air pollutants. The submission specifically argues that natural ecosystems should be excluded from the requirement to submit pollution prevention plans.

The document proposes a carbon offset mechanism to allow South African firms to reduce their carbon tax liability by up to 10% of actual emissions. It establishes that only South African-based credits from projects outside the carbon tax net are eligible to avoid double counting. The paper identifies a potential national demand for offsets of up to 30 million tonnes of CO2e per annum, with a projected supply exceeding 50 million tonnes, largely driven by land-use, forestry, and renewable energy projects. It suggests an initial reliance on international standards (CDM, VCS, GS, CCBS) while proposing the medium-term development of a domestic standard managed by the Designated National Authority (DNA), supported by an independent expert committee, a national registry, and accredited third-party verifiers.

The Centre for Environmental Rights (CER), representing several community and environmental groups, submitted a formal reply on 24 March 2014 challenging Eskom's applications for postponement from the Minimum Emission Standards (MES). The CER disputes Eskom's claims that its power stations have a marginal impact on air quality and health, arguing that Eskom's Atmospheric Impact Reports (AIRs) are anecdotal, use insufficient modeling domains, and fail to quantify the health risks associated with secondary PM2.5 formation and mercury emissions.

The Centre for Environmental Rights (CER), acting for several environmental justice organisations, submitted comments on the Department of Environmental Affairs' (DEA) Draft Air Quality Offset Policy. The CER and its clients oppose the use of offsets in principle, arguing they serve as a "cheap option to avoid compliance" with emission standards and could undermine the constitutional right to a healthy environment. The submission highlights significant gaps in the draft policy, including a lack of clear criteria for determining offsets, poor institutional capacity for monitoring and enforcement, and failure to address equity and distributional effects.

The Centre for Environmental Rights (CER), representing several environmental justice organisations, submitted comments on 21 February 2014 regarding the Draft National Atmospheric Emissions Inventory System (NAEIS) Reporting Regulations. The submission primarily argues that the draft regulations fail to ensure adequate public access to atmospheric emission data and provides recommendations to align the regulations with constitutional rights to information and a healthy environment.

The Centre for Environmental Rights (CER) objects to Eskom's request to increase particulate matter (PM) emission limits at the Duvha Power Station. CER argues that Eskom's application is based on flawed modelling, fails to account for severe health impacts, and contradicts the goals of the Highveld Priority Area. The document highlights Eskom's history of environmental non-compliance and poor planning, asserting that the requested 'grace period' for repairs is an opportunistic attempt to avoid meeting Minimum Emission Standards (MES).

The Centre for Environmental Rights (CER) argues that Eskom's requests to postpone compliance with the National Environmental Management: Air Quality Act (AQA) should be denied due to flawed atmospheric modelling, exaggerated compliance costs, and significant risks to human health. The CER contends that Eskom fails to meet the legal requirements for postponement, particularly regarding the impact on declared Priority Areas. Furthermore, the document critiques Eskom's proposal for emission offsets as lacking a legal basis and sufficient data, while highlighting that granting these postponements would lead to substantial increases in SO2, NOx, and PM10 emissions through 2020.

The report examines the five-year campaign by the Save Mapungubwe Coalition to protect the Mapungubwe World Heritage Site from the Vele Colliery project operated by Coal of Africa (CoAL). It analyzes three primary engagement strategies: strategic litigation to challenge mining licenses, bilateral negotiations to establish best-practice environmental standards, and multilateral participation in the Vele Colliery Environmental Management Committee (EMC). The document concludes that while litigation and negotiations have limitations, they provide essential leverage, and that inclusive multi-stakeholder governance via EMCs can effectively monitor corporate compliance. It also highlights the correlation between CoAL's non-compliance with environmental laws and the decline of its JSE share price.

The Centre for Environmental Rights (CER) argues that current proposed fracking regulations in South Africa are inadequate because they rely on industry standards and are housed under the Mineral and Petroleum Resources Development Act (MPRDA) rather than comprehensive environmental laws. The document advocates for a regulatory regime based on the Constitution and the National Environmental Management Act (NEMA), calling for a specialised inter-departmental unit to oversee authorisations and enforcement. Key recommendations include mandatory baseline environmental measurements, public disclosure of fracking fluid chemicals, a prohibition on using potable water, and the implementation of 'green completions' to eliminate gas venting and flaring. The CER emphasizes that fracking should only be permitted if it can be proven to contribute to sustainable development without causing irreparable harm to water resources or disadvantaged communities.

The Centre for Environmental Rights (CER), representing several community and environmental groups, submitted a response to the Nkangala District Municipality opposing Eskom's application to vary the atmospheric emission licence for the Kriel Power Station. The CER argues that the variation would permit increased emissions of particulate matter (PM10) and mercury, leading to significant public health risks and economic costs, while challenging Eskom's dispersion modelling and cost calculations for abatement technology.

The 'Air Quality Offset Policy' is a draft framework published by the Centre for Environmental Rights in January 2014. It proposes the use of environmental offsets—measures that counterbalance adverse atmospheric emissions—to balance South Africa's economic growth and industrial development with the constitutional right to a healthy environment. The policy outlines principles for offset design, specific application scenarios such as license variations or postponements, and the roles of applicants, licensing authorities, and communities in implementing these measures.