logo
SUBMISSIONS

Life After Coal Campaign submission to the Presidential Climate Commission on the Just Transition Framework

29 April 2022 - Download here.

groundWork and Earthlife Africa's comments on South Africa's new Nationally Determined Contribution

30 April 2021 - Download here.

groundWork's comment to NERSA on the Minister's determination on the procurement of 2 500 MW generation capacity from nuclear generation

05 February 2021 - Download here.

Comments on The Public Notices Published for the Intention to Consult On Various Environmental Management Instruments

08 September 2020 - Download here.

Request to The Minister to Revoke The Decision Regarding the Section 30 (A) (1) Directive Issued By DEFF For The Karpowership Gas to Power Project

18 August 2020 - Download here.

Low Emission Development Strategy

31 January 2019 - groundWork comment on the Low Emission Development Strategy.

Download the submission here.

Need for a Just Transition to Life After Coal

19 December 2018 - Letter to President Cyril Ramaphosa on the subject of the need for a just transition to life after coal.

Read the letter here.

Draft Electricity Integrated Resource Plan (IRP)

22 October 2018 - Government’s electricity plan (the Integrated Resource Plan, IRP) will result in thousands of South Africans dying prematurely because of pollution from coal fired power stations, fan the fires of climate change with increases in greenhouse gas emissions, and make electricity unaffordable for millions of poor South Africans who are already excluded from the economy.

Submission by groundWork to coincide with the release of its Coal Kills special report.

Environmental Health & Health Equity in South Africa

07 September 2018 - Submission to The United Nations Committee On Economic, Social And Cultural Rights, 64th Session, 24 September – 12 October 2018, South Africa.

Environmental rights and health rights can no longer be viewed as mutually exclusive issues; the submission supports and affirms this by bringing to the fore the state of environmental health and health inequity in South Africa.

Comments on the Climate Change Bill, 2018

08 August 2018 - Submission by the Life after Coal Campaign on the Climate Change Bill 2018.

Response to the National Planning Commission Energy Paper

04 April 2018 - groundWork and Earthlife Africa (Jhb) response to the National Planning Commission Energy Paper.

groundWork and the Church Land Programme (CLP) appeal exploration right

01 November 2017 - groundWork and the Church Land Programme (CLP) have appealed the exploration right granted to Rhino Oil and Gas (12/3/317 ER) on behalf of Rural Network, Sisonke Environmental Justice Network, Farm Eviction and Development Committee, Botha's Pass Community, Siyanqoba Rural Transformation Forum, Siyaphambili Emajuba Farm Dwellers Association and the Landless Peoples Movement.

During our engagement with these affected communities, it became apparent that they were not consulted and did not have prior knowledge of this application.

You can view the appeals documentation submitted by clicking on the links below:

Comment on the Steve Tshwete Local Municipality - 2017-2022 draft Integrated Development Plan.

Read the submission made by groundWork and the Highveld Environmental Justice Network (HEJN) here.

Comment on Draft Critical Infrastructure Protection Bill 2016

15 June 2017 - Read the submission made by groundWork dated 15 June 2016 here.

More than 2300 people die each year because of our addiction to coal energy.

31 March 2017 - Burning coal in Eskom's power stations cost South Africa, R30 Billion a year. This is from key research in response to the South African IEP which is the overall energy plan for liquid fuels (petrol, diesel, paraffin), gas and electricity. The IRP is the more detailed plan for electricity.

Both plans make projections of energy / electricity demand through to 2050 and consider how to supply that demand. The IEP contains four different scenarios which result in different levels of demand. The IRP does not refer to these scenarios but uses electricity demand projections developed by the CSIR.

groundWork sought assistance from a health economist to understand the impact of Eksom's Coal fired power stations on ones health and the economy. This was part of our submission to the Department of Energy.

You can download the document Health Impacts of Coal fired Power Plants in South Africa here and Integrated Energy Plan (IEP) and Integrated Resource Plan (IRP) 2016. (Comments by groundWork, Friends of the Earth, South Africa) here.

GROUNDWORK AND SDCEA APPEAL COLENSO ENVIRONMENTAL AUTHORISATION

3 March 2016 – groundWork and the South Durban Community Environmental Alliance (SDCEA), represented by the Centre for Environmental Rights on 1 March 2016 launched an appeal to the Minister of Environmental Affairs against the environmental authorisation granted to Colenso Power (Pty) Ltd for its proposed coal-fired power station near the town of Colenso.

Read the Appeal Document here.

SASOL'S OFFSET PLAN CONDONES NON-COMPLIANCE

29 January 2016 – groundWork has submitted its comments to SRK Consulting who is, on behalf of its client Sasol, coordinating the plans for the company's offset program.

Read the comments document here.

GROUNDWORK APPEALS NPC HAZARDOUS WASTE INCINERATOR

27 January 2016 – groundWork is appealing Natal Portland Cement’s environmental authorisation to burn ‘alternative fuels and resources’ at the company’s Simuma Works. This authorisation, granted by the MEC of the KwaZulu Natal Economic Development, Tourism and Environmental Affairs (EDTEA), as it exists is essentially a licence to operate a hazardous waste incinerator that can burn any industrial hazardous waste at the discretion of the licence holder.

Read the full media advisory here.

Read the appeal document here.

EDTEA form.

NEMWA National Policy on thermal treatment of hazardous and general waste.

Holcim-GTZ Guidelines on Co-processing Waste Materials.

ESKOM’S TARIFF CLAW BACK TO CRIPPLE RATEPAYERS

20 January 2016 – Eskom is asking for a tariff increase of about 8.6% in its Regulatory Clearing Account (RCA) [1] application to National Energy Regulator of South Africa’s (NERSA). If granted, this will bring the total 2016 tariff hike to 16.6%, sinking the poorest deeper into poverty and darkness.

Eskom’s requests for grossly inflated tariff hikes come round every year or, as in 2015, more than once a year. The energy utility has established a pattern of late and/or repeated application stretching back to 2008. This has the appearance of a tactic to forestall public consultation and put the National Energy Regulator of South Africa’s (NERSA) decision-making under pressure.

Read the full media advisory here.

Read groundWork's comment on the Eskom regulatory Clearing Account (RCA) submission to the National Energy Regulator of South Africa (NERSA) here.

GROUNDWORK APPEALS 600MW KIPOWER (PTY) LTD COAL POWER STATION

10 December 2015 – On behalf of groundWork, the Centre of Environmental Rights (CER) has filed an appeal in terms of the Section 43 of the National Environmental Management Act, 1998 against the Integrated Environmental Authorisation for the proposed construction of a 600 megawatt coal-fired independent power plant and associated infrastructure for KiPower (Pty) Ltd. near Delmas in the Mpumalanga Province.

Read the full submission here.

CLIMATE ‘CONTRIBUTIONS’ SPELL DISASTER FOR SOUTH AFRICA

27 August 2015 – In the lead up to the annual United Nations climate negotiations, the South African government has published its Intended Nationally Determined Contributions (INDC) discussion document [1], which states that South Africa is “firmly committed” to keeping global warming to less than 2˚C above pre-industrial levels. It adds that this target may be revised to “below 1.5˚C in light of emerging science, noting that global average temperature increase of 2˚C translates to up to 4˚C for South Africa by the end of the century”. 

Today, in its submission [2] to the Department of Environmental Affairs in response to the INDC document, groundWork [3] states:

“Following climate scientist James Hansen, the 2˚C target is a recipe for disaster. With temperatures about 0.85˚C above pre-industrial levels, millions of people already experience climate change as disastrous. Intensified heatwaves, droughts and storms have affected all parts of the world. Already, the deaths of half a million people a year are directly attributable to climate change. That figure will rise steeply in the next decades.”

Read the full press release here and the submission in response to the INDC document here.

SASOL AND THE PROPOSED CARBON TAX

29 July 2015 – In May this year, business and industry made representations to the Davis Tax Committee on Treasury's proposal for to introduce a carbon tax. The tenor of their arguments were that no more should be done to mitigate emissions and this was backed up by the claim, based on Sasol's 'emissions outlook', that South Africa's emissions are 'below target'. 

Here, we are posting links to:

You can also read an article carried in the Mail & Guardian, headed 'Corporate SA promotes carbon myths' which gives our view of the overall position taken by business by clicking here.

CIVIL SOCIETY AND COMMUNITY ORGANISATIONS TAKE ON MINERAL RESOURCES FOR AUTHORISING A COAL MINE INSIDE AN MPUMALANGA PROTECTED AREA

1 April 2015 - A broad-based coalition of eight civil society and community organisations launched an appeal to the Minister of Mineral Resources to set aside the Department of Mineral Resources’ decision to grant a mining right to a mining company inside a declared protected environment near Wakkerstroom in the Mpumalanga grasslands.

Read the full submission here.

ESKOM'S APPLICATIONS TO DELAY COMPLIANCE WITH AIR QUALITY LAWS: CIVIL SOCIETY GROUPS RESPOND TO FURTHER INFORMATION SUBMITTED BY ESKOM

16 October 2014 – On behalf of a group of civil society and community organisations, the CER submitted to the National Air Quality Officer additional objections to Eskom's applications to postpone compliance with minimum emission standards commencing on 1 April 2015, to ensure that the decision-makers are in possession of relevant information, as required by the Promotion of Administrative Justice Act, 2000.

Read the full submission here.

CIVIL SOCIETY AND COMMUNITY ORGANISATIONS CHALLENGE DRACONIAN SOUTH AFRICAN WEATHER SERVICE AMENDMENT BILL

23 January 2012 – Tomorrow, 24 January 2012, and 25 January 2012, Parliament will hold public hearings on the South African Weather Service Amendment Bill, 2011.

Many civil society and community organisations – groundWork, the South Durban Community Environmental Alliance (SDCEA), and the Vaal Environmental Justice Alliance (VEJA) - are particularly concerned about the offence the Amendment Bill proposes if an air pollution-related warning (which is not defined in the Bill) is issued without written permission from the South African Weather Service.

If the Bill is passed in its current format, this offence is likely to have negative implications for the environment, public health, and particularly, civil society participation in environmental governance and community information dissemination.

Read the submission made by the Centre for Environmental Rights on behalf of groundWork, the South Durban Community Environmental Alliance and the Vaal Environmental Justice Alliance here.