2014-05-30-fa57-email-from-sasol-to-dea-20-11-2013-2db5966aa2d5547e.pdf

This document is a submission from Sasol to the South African Department of Environmental Affairs (DEA) detailing the company's objections to the requirement that existing industrial plants meet 'new plant standards' for emissions by April 1, 2020. Sasol argues that retrofitting old facilities is often technically impossible due to space and configuration constraints, economically unviable, and potentially counterproductive to other environmental goals, such as carbon footprint reduction and water conservation.

• Sasol asserts that requiring existing plants to meet new plant standards is often impractical or impossible because many of its facilities were built between 1950 and 1980. Retrofitting is hindered by size and configuration constraints, and technology providers may refuse to guarantee performance levels for such old assets.
• The company argues that implementing new abatement technology would create conflicting environmental impacts, specifically increasing the national carbon footprint due to higher energy consumption and increasing water and land use for waste storage. Sasol notes that flue gas desulphurization is less viable in South Africa than in Europe or America due to water scarcity and the costs of transporting lime.
• Sasol identifies a direct conflict between the emission standards and the Department of Energy's National Energy Efficiency Strategy (GN1000 of 2012), stating that the energy intensity required for point source abatement would negatively impact sector efficiency targets.
• Regarding specific operations, Sasol claims that its steam generation plants in Sasolburg and Secunda cannot be converted to new standards due to extreme site congestion and the risk that lowering boiler temperatures for bag house installation would increase ambient H2S concentrations.
• The Natref refinery faces unique challenges because it is the only inland oil refinery in South Africa. Sasol argues that strict SO2 standards place Natref at a competitive disadvantage compared to coastal refineries and could threaten the security of fuel supply, particularly jet fuel for OR Tambo airport.
• Sasol contends that the current compliance timeframes are too optimistic, as their project implementation model for unique older assets typically takes more than five years for design, construction, and commissioning.
• The document highlights regulatory uncertainty caused by the 'postponement clause,' which Sasol's legal counsel suggests only allows for a maximum five-year extension. Sasol argues this is insufficient for major capital projects and requests a 'grandfather clause' or extensions of 15 to 20 years.
• Sasol expresses concern over the ability of three different tiers of government (national, provincial, and local) to set independent and potentially contradictory standards, which creates a volatile investment landscape for plants with 20-year payback periods.

APA

Centre for Environmental Rights (n.d.). 2014-05-30-fa57-email-from-sasol-to-dea-20-11-2013-2db5966aa2d5547e.pdf. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA57-Email-from-SASOL-to-DEA-20-11-2013.pdf?x21779

Chicago

Centre for Environmental Rights. 2014-05-30-fa57-email-from-sasol-to-dea-20-11-2013-2db5966aa2d5547e.pdf. n.d. https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA57-Email-from-SASOL-to-DEA-20-11-2013.pdf?x21779.

Wikipedia

{{cite report |author=Centre for Environmental Rights |title=2014-05-30-fa57-email-from-sasol-to-dea-20-11-2013-2db5966aa2d5547e.pdf |url=https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA57-Email-from-SASOL-to-DEA-20-11-2013.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centreforenvironmentalrightsnd20140530fa57emailfromsasoltodea201120132db5966aa2d5547epdf, author = {{Centre for Environmental Rights}}, title = {{2014-05-30-fa57-email-from-sasol-to-dea-20-11-2013-2db5966aa2d5547e.pdf}}, institution = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/06/2014-05-30-FA57-Email-from-SASOL-to-DEA-20-11-2013.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }