Centre for Environmental Rights – Advancing Environmental Rights in South Africa

• LAC comment on draft South African Renewable Energy Masterplan (July 2023): Gender equality, gender justice and women’s participation

• CER Submission on Kusile proposed stack bypass (21 April 2023)
• Potential health impacts of bypassing SO2 controls at Kusile – CREA Report
• Kusile bypass HIA with evaluation of Eskom AIR Briefing note (July 2023)
• gW and VEM Appeal Submissions – Annexure A July

• NERSA Consultation Document for Gas, Renewable and Hydrogen Partnership Strategy
• Life After Coal submission to NERSA on Gas, Renewable and Hydrogen Partnership Strategy

• Intention to adopt the National Web Based Environmental Screening Tool
• Screening Tool
• Intention to exclude the development and expansion of solar photovoltaic facilities and associated activities or infrastructure from the requirement to obtain environmental authorisation
• Life After Coal Comments on Solar PV Exclusion Notice and Proposed Screening Tool (7 October 2022)

• First Draft Implementation Plan WCCCRS
• groundWork ACA Comments Western Cape Climate Change Response Strategy Implementation Plan (26 September 2022)

On 25 March 2022, the Life After Coal Campaign submitted comments on the Second Amendment Bill of the Electricity Regulation Act (ERA) 94 of 2006 published by the Department of Mineral Resources and Energy in GN 1746 of 10 February 2022.

On 31 January 2022, the Life After Coal Campaign submitted comments on the Gas Master Plan Basecase Report to the Department of Mineral Resources and Energy.

CER Submission on Government Notice titled “Consultation on applications received for the Exclusion of Waste Streams or a portion of such waste stream from the definition of waste for the purposes of beneficial use” under the Waste Exclusion Regulations, 2018 (16 September 2019)

• South African Services Amendment Bill, 2011
• CER comments on the South African Weather Services Amendment Bill, 2011 (12 January 2012)
• South African Weather Services Amendment Bill, 2013
• South African Weather Services Amendment Act, 2013

• Draft Air Quality Offset Policy (January 2014)
• CER comments on the Draft Air Quality Offset Policy (21 February 2014)
• Draft Air Quality Offsets Guideline (26 June 2015)
• CER comments on the Draft Air Quality Offsets Guideline (27 July 2015)
• Air Quality Offsets Guideline (18 March 2016)

• Draft Nkangala District Municipality (NDM) Air Quality Management Plan (AQMP) and Draft Air Quality Management By-law (January 2015)
• CER preliminary comments on the first draft NDM AQMP and Air Quality Management By-law and annexures A, B and C (29 April 2016)
• Draft NDM AQMP (6 May 2015)
• Draft NDM Air Quality Management By-law (6 May 2015)
• CER comments on the Draft AQMP and the Draft By-law submitted (27 May 2015) and annexures 1, 2, 3, 3A and 4
• NDM Air Quality Management By-law (10 June 2016)

• CER submissions on the NPC Energy Discussion Paper (26 April 2018)
  • Annexure A: UCT Energy Research Centre’s presentation “An assessment of new coal plants in plants in South Africa’s electricity future” (27 March 2018)

• Draft Dust Control Regulations (7 December 2012)
• CER submissions on Draft Dust Control Regulations (5 February 2013)
• National Dust Control Regulations (1 November 2013)
• CER submissions to the Minister requesting the strengthening of the Dust Control Regulations and annexures A, B, C and D (16 October 2015)
• Minister’s response (26 February 2016)
  • Annexure A
• CER’s follow-up letter to the Minister of Environmental Affairs (26 October 2016)
• CER submissions on the proposed amendments to the Dust Control Regulations (30 November 2017)
• Notice of intention to amend the Dust Control Regulations (25 May 2018)
• CER submissions on the proposed amendments to the Dust Control Regulations (25 June 2018)

• Draft National Atmospheric Emission Inventory System Reporting Regulations (22 January 2014)
• CER comments on the  Draft National Atmospheric Emission Inventory System Reporting Regulations (21 February 2014)
• Draft National Atmospheric Emission Reporting Regulations (18 July 2014)
• CER comments on Draft National Atmospheric Emission Reporting Regulations (18 August 2014)
• National Atmospheric Emission Reporting Regulations (2 April 2015)

• Draft Declaration of Greenhouse Gases as Priority Air Pollutants (14 March 2014)
• Draft National Pollution Prevention Plan Regulations (14 March 2014)
• CER comments on the 2014 Draft Declaration (10 April 2014)
• CER additional comments on the Draft Declaration (14 April 2014)
• Draft Declaration of Greenhouse Gases as Priority Pollutants (8 January 2016)
• Draft National Pollution Prevention Plan Regulations (8 January 2016)
• CER comments on the Draft Declaration and Draft Pollution Prevention Plan Regulations (8 February 2016)
• National Greenhouse Gas Emission Reporting Regulations (3 April 2017)

• Draft National Greenhouse Gas Emission Reporting Regulations (5 June 2015)
• CER comments on the Draft National Greenhouse Gas Emission Reporting Regulations (4 August 2015)
• Draft National Greenhouse Gas Emission Reporting Regulations (7 June 2016)
• CER comments on the Draft National Greenhouse Gas Emission Reporting Regulations and annexures A, B, C and D (7 July 2016)
• National Greenhouse Gas Emission Reporting Regulations (3 April 2017)
• Draft amendments to the National Greenhouse Gas Emissions Reporting Regulations (6 September 2019)
• Comments on Proposed Amendment to Greenhouse Gas Reporting Regulations on behalf of groundWork and Earthlife Africa (7 October 2019)
  • Annexure A – CER Comments on Draft GHG Reporting Regs (4 August 2015)
  • Annexure B – CER Submissions Draft GHG Reporting Regs (7 July 2016)
  • Annexure C – CER letter re GHG Regulations (19 January 2018)
  • Annexure D – Life After Coal letter to Minister Hanekom – Climate Change Bill (20 November 2018)
  • Annexure E – Response to CER – Implementation of the GHG Reporting and Pollution Prevention Plan Regulations (21 February 2018)

• CER PAMs Approach and Methodology Submission (18 August 2017)
• CER comments on PAMs Draft Report (6 April 2018)

• Draft Carbon Tax Bill, explanatory memorandum and media statement (2 November 2015)
• CER comments on the Draft Carbon Tax Bill (7 December 2015)
• Draft Carbon Tax Bill 2017 (14 December 2017)
• Comments on Draft Carbon Tax Bill 2017 – a Joint Submission by Centre for Environmental Rights and Greenpeace Africa (29 March 2018)
• Taxation Laws Amendment Bill, Explanatory Memorandum and Media Release (29 July 2022)
• Life After Coal Comments (29 August 2022)

• Notice and Draft 8^th National Greenhouse Gas Inventory Report
• Life After Coal Comments

• Draft Regulations for the Procedure and Criteria to be Followed in the Determination of an Administrative Fine in terms of section 22A of the National Environmental Management Air Quality Act 2004 (25 September 2015)
• CER comments on the draft Regulations (9 November 2015)
• Regulations for the Procedure and Criteria to be Followed in the Determination of an Administrative Fine in terms of section 22A of the Act (18 March 2016)

• CER letter to the Director General, Department of Environmental Affairs, calling for the publication, for comment, of the Draft Strategy to Address Air Pollution in Dense Low Income Settlements (7 April 2015)
• Draft Strategy to Address Air Pollution in Dense Low-Income Settlements (24 June 2016)
• CER comments on the Draft Strategy (29 August 2016)

• CER comments on the Draft Integrated Resource Plan and Integrated Energy Plan (31 March 2017)
  • Annexure A
• CER’s additional written comments on the IRP: update, assumptions, base case and observations, revision 1, and the IEP: missing costs (11 August 2017)
  • CER’s letter to the Council for Scientific and Industrial Research (11 August 2017)
• Further submissions by the CER on the draft IRP and IEP update (20 November 2017)
• CER written comments on the Draft IRP Update 2018 (26 October 2018)
  • Annexure A: A. Allison, R. Wilson, D. Glick and J. Frost, Comments on South Africa 2018 Integrated Resources Plan prepared for the Centre for Environmental Rights, Synapse Energy Economics Inc. (24 October 2018)
• Greenpeace Africa submission on the Draft IRP Update 2018 (26 October 2018):
  • Technical Commentary
  • Legal Commentary
• groundWork written comments on the Draft IRP Update 2018 (26 October 2018)
• CER’s comments to the Portfolio Committee on Environmental Affairs on the Draft Integrated Resource Plan for Electricity, 2018 (5 October 2018)

• CER comments on the draft National Framework for Air Quality Management (22 August 2012)
• CER comments on the draft National Framework for Air Quality Management (16 April 2013)
• CER’s preliminary comments on the draft review of the National Framework for Air Quality Management (29 September 2017)
• Notice of intention to amend the National Framework for Air Quality Management (25 May 2018)
• CER comments on the draft National Framework for Air Quality Management (29 June 2018)

• CER Submissions on the Proposed Priority Area Implementation Regulations and Media Release (8 September 2022)

• Notice of intention to amend the list of activities which result in atmospheric emissions, which have or may have a significant detrimental effect on the environment, including health, social conditions, economic conditions, ecological conditions or cultural heritage regulations (25 May 2018)
• CER submissions on proposed amendments to the list of activities which result in atmospheric emissions, which have or may have a significant detrimental effect on the environment, including health, social conditions, economic conditions, ecological conditions or cultural heritage regulations (25 June 2018)
• CER objections to the 22 May 2019 proposed amendments to the list of activities and associated MES identified in terms of Section 21 of the National Environmental Management: Air Quality Act 39 of 2004 (5 July 2019)
• CER Submissions on the Proposed Priority Area Implementation Regulations (5 September 2022) and Media Release

• Draft Waste Stream Regulations (12 January 2018)
• CER comments on Draft Waste Stream Regulations (12 February 2018)

• Life After Coal comments Climate Change Bill (2022)
• Tabled Climate Change Bill (2022)
• Draft Climate Change Bill (8 June 2018)
• CER comments on Draft Climate Change Bill (8 August 2018)
• CER oral submission to PPCEFF – Climate Change Bill (7 September 2022)

Comments on NEMLAB [B14C-2017]

• CER’s Table of Comments on NEMLAB [B14-2017] and Cover Letter to Parliamentary Portfolio Committee on Environmental Affairs (19 April 2017)

Comments on NEMLAB [B14D-2017]

• CER’s Table of Comments: Waste and Air Quality and Cover Letter to the NCOP’s Select Committee on Land Reform, Environment, Mineral Resources & Energy (24 January 2020)
• CER’s Additional Table of Comments submitted to the NCOP’s Select Committee on Land Reform, Environment, Mineral Resources & Energy (31 January 2020)

Comments on Determination 1

• Centre for Environmental Rights on behalf of Life After Coal Campaign – Comments on Consultation Paper 1 (14 April 2020)

Comments on Determination 2

• Centre for Environmental Rights on behalf of Life After Coal Campaign – Comments on Consultation Paper 2 (7 May 2020)

Life After Coal Campaign’s comments to the Department of Mineral Resources and Energy on the Draft Regulations Amending the Electricity Regulations on New Generation Capacity 2011 (submitted on 4 June 2020)

• CER’s comments on South Africa’s draft updated NDC under the Paris Agreement (submitted 30 April 2021)
• Annexure 1 (Comparison of South Africa’s draft updated mitigation NDC to its mitigation fair share)

• See Life after Coal Campaign’s submission on the Draft National Guideline for Consideration of Climate Change Implications in applications for Environmental Authorisations, Atmospheric Emission Licences and Waste Management Licences (submitted 23 July 2021)