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1,469 documents from Centre for Environmental Rights
REQUEST FOR REASONS: NERSA ELECTRICITY GENERATION LICENCE FOR KARPOWERSHIP RICHARD’S BAY, NGQURA AND SALDANHA
The Centre for Environmental Rights, representing groundWork, has requested that the National Energy Regulator SA (NERSA) release the approval documents, reasons, charge rates, and power purchase agreements related to the electricity generation licences granted on 21 September 2021 for Karpowership projects in Richard's Bay, Ngqura, and Saldanha.
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Document type: Statement
LETTER OF DEMAND - INTEGRATED RESOURCE PLAN FOR ELECTRICITY 2019 AND THE MINISTERIAL DETERMINATION ON THE PROCUREMENT OF 1 500 MW OF NEW GENERATION CAPACITY FROM COAL
The Centre for Environmental Rights (CER), acting for groundWork, Vukani Environmental Justice Movement in Action, and the African Climate Alliance, issued a letter of demand to the Minister of Mineral Resources and Energy and the National Energy Regulator of South Africa (NERSA). The letter demands the abandonment of the procurement of 1,500 MW of new coal-generation capacity as specified in the Integrated Resource Plan for Electricity 2019 (IRP 2019) and a September 2020 ministerial determination, citing economic, environmental, and climate risks.
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Document type: Statement
INTEGRATED RESOURCE PLAN 2019 AND THE MINISTERIAL DETERMINATION ON THE PROCUREMENT OF NEW GENERATION CAPACITY FROM RENEWABLES, STORAGE, GAS AND COAL
The Centre for Environmental Rights (CER), representing groundWork, Vukani Environmental Justice Movement in Action, and the African Climate Alliance, has written to the Minister of Mineral Resources and Energy and the National Energy Regulator SA (NERSA). The letter objects to the inclusion of new fossil fuel generation capacity in the Integrated Resource Plan (IRP) 2019 and a September 2020 ministerial determination, specifically opposing 1500 MW of new coal capacity. The CER requests clarity on whether the IRP 2019 will be updated by the end of 2021, citing a June 2021 announcement by President Ramaphosa regarding the Electricity Regulation Act that could unlock over 5000 MW of embedded generation capacity not currently accounted for in the plan.
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Document type: Statement
Climate impacts in southern Africa during the 21st Century
This report by the Centre for Environmental Rights, authored by Robert Scholes and Francois Engelbrecht of the Global Change Institute, details the human-caused climate impacts affecting southern Africa. It highlights the region's status as a climate 'hotspot' where warming is occurring at twice the global average rate, leading to severe risks for agriculture, water security, human health, and biodiversity. The document emphasizes that the severity of these impacts depends on global mitigation efforts, with warming above 2°C posing catastrophic risks to staple crops and livestock.
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Document type: Report
The South African Risk Mitigation Power Producers Procurement Programme (RM4P): A techno-economic evaluation of the underlying design of the request for proposals (RFP) and the resultant impact on the outcomes of the RM4P
This techno-economic evaluation by Clyde Mallinson analyzes the South African Risk Mitigation Power Producers Procurement Programme (RM4P). The report argues that the Request for Proposals (RFP) was designed for gas-dominated projects, creating restrictive rules that unfairly penalize renewable energy and storage projects, thereby making gas projects appear more cost-competitive than they are. The author suggests that a technology-agnostic, system-integrated approach could significantly reduce tariffs and carbon emissions.
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Document type: Report
Climate Change Implications for SA’s Youth
This expert report by Nicholas King, commissioned by the Centre for Environmental Rights, analyzes the projected physical, socio-economic, and ecological impacts of climate change on youth and future generations in South Africa from 2021 through 2060 and beyond. It argues that under current 'business as usual' trajectories, large portions of the country may become uninhabitable, leading to systemic collapses in food and water security, infrastructure, and mental wellbeing.
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Document type: Report
OBJECTION BY GROUNDWORK SOUTH AFRICA TO KARPOWERSHIP SA RICHARDS BAY (RF) (PTY) LIMITED'S APPLICATION FOR AN ELECTRICITY GENERATION LICENCE SUBMITTED TO THE NATIONAL ENERGY REGULATOR OF SOUTH AFRICA
Groundwork South Africa submitted an affidavit to the National Energy Regulator of South Africa (NERSA) objecting to Karpowership SA Richards Bay's application for an electricity generation licence. The objection argues that the project fails to meet the requirements of the Electricity Regulation Act (ERA) and the National Energy Regulator Act (NERA), citing severe environmental risks, lack of necessary permits, and the existence of cheaper, cleaner energy alternatives.
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Document type: Statement
SUBMISSIONS ON THE GAS AMENDMENT BILL [B9 – 2020] PUBLISHED FOR COMMENT ON 25 JUNE 2021
The Centre for Environmental Rights (CER), on behalf of itself and groundWork, submitted comments on the draft Gas Amendment Bill [B9 – 2020] to the Portfolio Committee on Mineral Resources and Energy. The CER argues that the Bill fails to account for the climate emergency, lacks adequate public consultation and access to information, and irregularly encroaches upon environmental regulatory powers reserved for the Minister of Forestry, Fisheries and Environment.
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Document type: Statement
Final Synthesis Report
This final synthesis report by the Centre for Environmental Rights provides strategic and technical guidance on managing sulphur dioxide (SO2) emissions from old solid fuel combustion plants in South Africa, specifically focusing on Eskom and Sasol facilities. The report utilizes a cost-benefit analysis (CBA) to recommend minimum emission standards (MES) based on plant lifetime and economic viability, concluding that reducing SO2 emissions is technologically feasible and provides significant net societal benefits through improved public health and macroeconomic growth.
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Document type: Report
THE CENTRE FOR ENVIRONMENTAL RIGHTS COMMENTS ON THE DRAFT NATIONAL MINE CLOSURE STRATEGY 2021
The Centre for Environmental Rights (CER) provided written comments on the Draft National Mine Closure Strategy 2021, published by the Department of Mineral Resources and Energy (DMRE). While supporting the initiative to increase certainty in mine closure and rehabilitation, the CER argues that the strategy must better protect mining-affected communities, ensure meaningful public participation from the pre-feasibility stage, and align strictly with existing environmental legislation like the National Environmental Management Act (NEMA).
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Document type: Statement
COMMENTS ON THE INTENDED DRAFT GUIDELINE FOR CONSIDERATION OF CLIMATE CHANGE IMPLICATIONS IN APPLICATIONS FOR ENVIRONMENTAL AUTHORISATIONS, ATMOSPHERIC EMISSIONS LICENSES AND WASTE MANAGEMENT LICENCES
The Centre for Environmental Rights (CER), representing groundWork and Earthlife Africa, submitted comments on July 23, 2021, regarding the Department of Forestry, Fisheries and the Environment's (DFFE) draft Guideline for considering climate change implications in environmental authorisations and licenses. While welcoming the initiative, the CER argues that the draft is insufficient to address the climate crisis and fails to meet the legal requirements of the Constitution and the National Environment Management Act (NEMA). The submission advocates for a 1.5°C warming limit as the primary benchmark for emissions assessments rather than Nationally Determined Contributions (NDCs), and calls for the inclusion of social costs of carbon and full lifecycle GHG emissions in project evaluations.
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Document type: Statement
NERSA ELECTRICITY GENERATION LICENCE APPLICATIONS FOR KARPOWERSHIP RICHARD’S BAY, NGQURA AND SALDANHA
The Centre for Environmental Rights (CER), acting on behalf of groundwork, wrote to the National Energy Regulator SA (NERSA) on 6 July 2021 to request a 90-day extension for commenting on electricity generation licence applications for three Karpowership gas power projects. The CER argues that the public participation process is flawed and that the projects' national significance warrants wider advertisement beyond local newspapers.
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Document type: Statement
COMMENTS ON POTENTIAL IMPACTS OF PROPOSED NEW COAL GENERATION UNDER THE SOUTH AFRICA 2019 INTEGRATED RESOURCE PLAN
This report by Dr. Ranajit Sahu evaluates the technical and environmental feasibility of adding 1,500 MW of new coal generation as proposed in South Africa's 2019 Integrated Resource Plan (IRP). The author argues that 'clean coal' is a myth, asserting that any new capacity will inevitably cause significant air pollution and greenhouse gas emissions, regardless of the high-efficiency, low-emission (HELE) technologies employed.
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Document type: Report
OBJECTION TO THE NIFPP WATER USE LICENCE APPLICATION
The Centre for Environmental Rights, acting for groundWork, submitted a formal objection on 18 June 2021 to the Water Use Licence (WUL) application for the Nseleni Independent Floating Power Plant (NIFPP) at the Port of Richards Bay. The objection argues that the 12-page application is 'woefully deficient and incomplete,' failing to provide necessary data on water resource impacts, climate change, and the full scope of associated infrastructure to allow for an informed decision.
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Document type: Statement
COMMENTS ON DRAFT REGULATIONS FOR THE USE OF WATER FOR GAS EXPLORATION AND PRODUCTION
The Centre for Environmental Rights (CER) submitted comments on June 7, 2021, regarding the draft Regulations for the use of water for gas exploration and production in South Africa. While welcoming the goal of protecting water resources, the CER argues that the draft regulations are insufficient to protect surface and underground water from the risks of hydraulic fracturing and underground coal gasification (UCG), particularly in the context of climate change.
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Document type: Statement
ENVIRONMENTAL IMPACT ASSESSMENT FOR THE PROPOSED METALLURGICAL CLUSTER OF THE MUSINA-MAKHADO SPECIAL ECONOMIC ZONE
The Centre for Environmental Rights (CER), representing Earthlife Africa, groundWork, and the Mining and Environmental Justice Community Network of South Africa (MEJCON-SA), submitted a formal objection to the Department of Economic Development Environment and Tourism in Limpopo regarding the Environmental Impact Assessment (EIA) for the Musina-Makhado Special Economic Zone (MMSEZ) metallurgical cluster. The CER argues that the Final Environmental Impact Report (FEIR) contains fatal flaws, including insufficient public participation and missing critical data on water and energy, and asserts that the application should have been refused by the regulatory deadline of 19 May 2021.
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Document type: Statement
Comment on proposed amendment to transitional provisions in the regulations pertaining to Financial Provisioning for the Rehabilitation and Remediation of Environmental Damage caused by Reconnaissance, Prospecting, Exploration, Mining or Production Operations
The Centre for Environmental Rights (CER) submitted a comment on 20 May 2021 objecting to a proposed amendment by the Minister of Environmental Affairs to extend the transitional period for mining right holders to comply with the 2015 Financial Provision Regulations.
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Document type: Statement
SUBMISSIONS ON THE APRIL 2021 PROPOSED AMENDMENT TO FINANCIAL PROVISION REGULATIONS, 2015, AS AMENDED
The Centre for Environmental Rights (CER) submitted a formal objection on 20 May 2021 to the Department of Forestry, Fisheries and the Environment regarding proposed amendments to the Financial Provision Regulations, 2015. The CER opposes the extension of the transitional period for certain right or permit holders to comply with these regulations, arguing that such delays increase the risk of environmental degradation and mine abandonment.
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Document type: Statement
APPEAL PURSUANT TO SECTION 43(2) OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 AGAINST THE DECISION TO RE-ISSUE THE ENVIRONMENTAL AUTHORISATION GRANTED TO RICHARDS BAY GAS TO POWER 2 (PTY) LTD - AUTHORISATION NUMBER 14/12/16/3/3/2/867
This document is a cover letter from the organization groundWork to the South African Minister of Forestry, Fisheries and Environment, formally lodging an appeal under Section 43(2) of the National Environmental Management Act, 1998. The appeal seeks to set aside a decision made on 31 March 2021 by the Chief Director to re-issue an environmental authorisation (number 14/12/16/3/3/2/867) to Richards Bay Gas to Power 2 (Pty) Ltd.
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Document type: Statement
Short Heads of Argument for First Respondent
This document contains the Short Heads of Argument filed on 11 March 2021 by the First Respondent, Uthaka Energy (Pty) Ltd, in the High Court of South Africa (Gauteng Division, Pretoria). Uthaka argues against an urgent application for an interim interdict brought by the Mining and Environmental Justice Community Network of South Africa and others, which seeks to stop the commencement of the Yzermyn Underground Coal-mining Project. Uthaka contends that it possesses all necessary statutory authorisations and that the application lacks urgency, a prima facie right, and a reasonable apprehension of irreparable harm.
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Document type: Briefing