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The report evaluates the CCIA for the Tetra4 Cluster 2 gas field expansion, which includes up to 400 test wells and 300 production wells. The author argues that the CCIA fails to meet South African legal requirements for a full life-cycle emissions assessment, specifically citing the omission of Scope 3 emissions from the final impact determination and several errors in Scope 1 calculations. Key technical failures identified include the use of outdated global warming potential (GWP) values, unrealistic flaring efficiency assumptions, and the omission of methane emissions from well drilling and operational gas production. Additionally, the report finds that the CCIA provides an unsupported claim that the project's LNG will replace more GHG-emitting fuels, while failing to account for the transport of 40% of the produced LNG.

The report critiques Tetra4's Cluster 2 gas expansion, citing significant data gaps in structural geology and hydrogeology. The author argues that the company's groundwater flow models and contamination simulations for methane and total dissolved solids (TDS) are unreliable because they ignore the complex nature of fractured-rock aquifers. Furthermore, the report contends that the proposed monitoring network is inadequate, relying on repurposed water-supply wells rather than strategically placed monitoring wells, and lacks essential analytical testing for carcinogens and radioisotopes.

This document is an appeal submitted by groundWork and the Vukani Environmental Justice Movement in Action against a decision by the National Air Quality Officer (NAQO) to grant Eskom a postponement of compliance with Minimum Emission Standards (MES) for the Kusile Power Station. The Appellants argue that the decision is unlawful, violates constitutional rights to a healthy environment, and was based on flawed health and atmospheric impact assessments and unfounded claims regarding the reduction of load shedding.

The document assesses the impact of operating three units at the Kusile power station without Flue Gas Desulfurization (FGD) from December 1, 2023, to March 31, 2025. It finds that this bypass will lead to a 6-fold increase in SO2 emissions and a 40% increase in mercury emissions, resulting in approximately 670 excess deaths and R16.8 billion in economic health damages. The authors argue that Eskom's own health impact estimates are unrealistically low because they use outdated modeling tools, ignore mercury emissions, and only consider a small 50 km geographic radius.

The Centre for Environmental Rights (CER) issued a statement to the Petroleum Agency of South Africa (PASA) expressing concerns over transparency, environmental monitoring, and the lack of Climate Change Impact Assessments (CCIAs) for upstream gas and petroleum activities.

The Constitutional Court of South Africa ruled that Parliament failed its constitutional obligation to facilitate public involvement regarding material amendments to the National Environmental Management Laws Amendment Act 2 of 2022. Specifically, the court found that the expanded definitions of "waste", "commercial value", and "trade in", as well as a transitional provision, were introduced without sufficient public consultation. The court declared these provisions invalid and unconstitutional, noting that the expanded definition of "waste" could have severe impacts on the steel and fertilizer industries by including by-products and co-products as waste, potentially leading to criminal penalties including fines up to R10 million or 10 years imprisonment.

The Centre for Environmental Rights, representing MEJCON-SA and MACUA, submitted a formal objection on May 9, 2023, against Tetra4 (Pty) LTD's application to amend its Water Use Licence (WUL) for the Cluster 2 expansion of gas and helium production near Virginia, Free State. The objection argues that the Integrated Water and Waste Management Plan (IWWMP) fails to adequately assess risks of groundwater contamination, radioactive waste, municipal water stress, and the compounding effects of climate change on a region critical for South African food security.

This document is a formal objection letter from the Centre for Environmental Rights (CER), on behalf of the Mining and Environmental Justice Community Network of South Africa (MEJCON-SA) and Mining Affected Communities United in Action (MACUA), regarding Tetra4's application to amend its Water Use Licence (WUL) for the Cluster 2 expansion of gas and helium production near Virginia, Free State. The document includes the original objections and the corresponding responses from Tetra4, focusing on risks to groundwater, radioactive contamination, waste management, and the impacts of climate change on water security.

A response from the Petroleum Agency SA (PASA) to the Centre for Environmental Rights regarding the regulation of upstream gas and petroleum activities, addressing public access to rights, environmental inspectors, and the status of hydraulic fracturing.

The Centre for Environmental Rights (CER) submitted a legal argument to the High Court of South Africa stating that, as a registered and accredited law clinic that provides free legal services and does not handle client funds or property, it is legally entitled to litigate without a fidelity fund certificate or a trust account.

The Gauteng High Court dismissed a review application by Industrial Zone (Pty) Ltd, upholding the MEC's decision to require a stream to remain in its natural course rather than being diverted for a light industrial development. The court found the Department's decision to be rational and reasonable under the Promotion of Administrative Justice Act (PAJA), while noting that the landowner maintains a duty to rehabilitate the stream.

The Life after Coal Campaign and the Fair Finance Coalition Southern Africa argue that the JET-IP is heavily skewed toward private sector interests and large-scale infrastructure, specifically green hydrogen, at the expense of community-led renewable energy and social investment. They highlight critical gaps in policy alignment, the lack of transparency regarding debt and loan agreements, and the failure to adequately address the health impacts of air pollution at the Medupi and Kusile power stations. The authors call for a reprioritization of funding toward transmission grid strengthening and socially owned energy models, while warning that the current approach to decommissioning coal plants, as seen at Komati, lacks the necessary community participation to be considered 'just'.

The document evaluates the consequences of bypassing Flue Gas Desulfurization (FGD) systems at the Kusile power station. It projects a six-fold increase in SO2 emissions and a 40% increase in mercury emissions, leading to an estimated 670 excess deaths and R16.8 billion in societal costs.

The document argues that the Upstream Petroleum Resources Development Bill (B13 - 2021) is fatally flawed because it seeks to "accelerate exploration and production" of oil and gas, which contradicts South Africa's climate commitments and the global goal of net zero by 2050. The authors highlight significant administrative shortcomings, specifically the lack of a clear definition for "interested and affected party" (IAP) and inadequate consultation requirements for most application types. Furthermore, the Bill is described as being in conflict with the One Environmental System (OES) by attempting to legislate on environmental matters that fall under the exclusive purview of the Minister for Forestry, Fisheries and the Environment. The submission also calls for the incorporation of Free, Prior and Informed Consent (FPIC) and a robust Social and Labour Plan (SLP) framework to protect vulnerable communities from the health and economic risks associated with petroleum extraction.

The Gauteng High Court dismissed an application to review the granting and transfer of mining rights to Aquila Steel and Motjoli Iron Ore, ruling that the initial award under the previous regulatory regime was lawful and that the court lacked the technical expertise to override executive decisions on environmental impacts.

The Life After Coal Campaign opposes Eskom's plan to install temporary bypass stacks at the Kusile power station, which would allow unabated SO2 emissions to restore generating capacity. The campaign argues that this proposal poses grave risks to human health, potentially causing up to 1,362 air pollution-related deaths and R25 billion in societal costs over 36 months at high utilization. They challenge the claim that the bypass will restore 2,160 MW, noting the plant's historical 33% capacity performance. Instead of the bypass, the campaign proposes investing the funds into solar PV and wind installations to accelerate the coal phase-out.

The report argues that the proposed Lephalale Coal and Power Project (LCPP) poses substantial health risks to surrounding communities in Limpopo, South Africa. It critiques the project's official Air Quality Impact Assessment (AQIA) for failing to provide quantifiable health risk estimates and for relying on weak national air quality standards. In contrast, the report supports findings from the Centre for Research into Energy and Clean Air (CREA), which identifies significant morbidity and mortality risks and an 'unfunded liability' of US$33.6 billion in externalised health costs. The author provides a comprehensive review of peer-reviewed literature linking coal-related pollutants—including particulate matter (PM2.5, PM10), nitrogen oxides, and mercury—to respiratory, cardiovascular, neurocognitive, and maternal health disorders, as well as various cancers.

The submission argues that the GHCS was developed without sufficient transparency or civil society participation and warns against over-investing in a speculative green hydrogen export market at the expense of addressing South Africa's urgent electricity crisis. It calls for a strict definition of 'green hydrogen' based on additionality, comprehensive cost-benefit analyses, and robust safety and environmental regulations before public funds are committed.

The document challenges the National Air Quality Officer's (NAQO) decisions to allow Eskom to delay compliance with emission standards. It argues that such postponements are unlawful under the National Environmental Management: Air Quality Act (AQA) and the 2017 National Framework, particularly for plants in the Highveld Priority Area (HPA). The submission provides evidence of Eskom's extensive history of emission exceedances and the resulting health costs, including thousands of projected premature deaths. It further asserts that the technology to abate sulphur dioxide (SO2) is feasible and economically beneficial, contradicting Eskom's claims of impracticality.

Two environmental organizations, groundWork and the South Durban Community Environmental Alliance (SDCEA), have authorized the Centre for Environmental Rights to appeal an environmental authorisation granted on 22 November 2022. The authorisation allows Phakwe Richards Bay Gas Power 3 (Pty) Ltd to develop and operate a 2000 MW gas-to-power plant in Richards Bay IDZ Zone 1F.