ESKOM’S APPLICATION FOR EXEMPTION FROM MINIMUM EMISSION STANDARDS AND POSTPONEMENT OF THE MINIMUM EMISSION STANDARDS TIMEFRAMES FOR ESKOM POWER STATIONS

The Centre for Environmental Rights (CER), representing several community and environmental groups, submitted comments on August 23, 2013, regarding uMoya-NILU Consulting's Plan of Study (PoS). The PoS was designed to support Eskom's applications for exemptions and postponements of Minimum Emission Standards (MES) for its power stations. The CER argues that the PoS is too narrow in scope, fails to include critical pollutants like PM2.5, uses inappropriate modelling software for near-field impacts, and lacks a mechanism to verify model outputs against real-world ambient measurements.

• The Plan of Study (PoS) is criticized for focusing primarily on compliance with ambient air quality standards rather than conducting a comprehensive assessment of impacts on health, social, economic, and ecological conditions as required for an Atmospheric Impact Report (AIR) under Section 30(a) of the National Environmental Management: Air Quality Act, 2004.
• The CER asserts that PM2.5 must be included in the modelling because it is a primary and secondary pollutant with serious health risks, and national ambient air quality standards for PM2.5 were promulgated on June 29, 2012.
• The proposal to model each coal-fired power station as an isolated source with a 60x60km receptor domain is deemed insufficient due to the magnitude of emissions and the clustering of stations in the Vaal Triangle, Highveld, and Waterberg Priority Areas. The CER recommends a regional scale approach to account for cumulative impacts.
• The CER challenges the use of CALPUFF for near-source modelling (under 50km), noting that both the US EPA and the Department of Environmental Affairs (DEA) recommend AERMOD for these distances. They suggest that CALPUFF's predictive accuracy for near-field applications is lower than other models.
• The PoS is criticized for not proposing a comparison between modelling outputs and actual ambient measurements. The CER argues that without this 'reality check', the credibility of 'what-if' scenarios is undermined because models are sensitive to assumed parameters.
• The CER argues that using annual average emission rates for 2010-2012 to estimate hourly and daily concentrations is unacceptable, as actual emission rates can vary by 30% to 40%, potentially underestimating short-term adverse health effects.
• Concerns are raised regarding the liquid fuel-fired power stations Acacia and Port Rex, specifically their short stack heights of 14m and their location in urban areas, which may lead to significant impacts on surrounding communities despite their smaller size compared to coal units.

APA

Centre for Environmental Rights (2013). ESKOM’S APPLICATION FOR EXEMPTION FROM MINIMUM EMISSION STANDARDS AND POSTPONEMENT OF THE MINIMUM EMISSION STANDARDS TIMEFRAMES FOR ESKOM POWER STATIONS. https://cer.org.za/wp-content/uploads/2014/03/4_CER-submissions_Plan-of-Study_23-August-2013_final.pdf?x21779

Chicago

Centre for Environmental Rights. ESKOM’S APPLICATION FOR EXEMPTION FROM MINIMUM EMISSION STANDARDS AND POSTPONEMENT OF THE MINIMUM EMISSION STANDARDS TIMEFRAMES FOR ESKOM POWER STATIONS. 2013. https://cer.org.za/wp-content/uploads/2014/03/4_CER-submissions_Plan-of-Study_23-August-2013_final.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=ESKOM’S APPLICATION FOR EXEMPTION FROM MINIMUM EMISSION STANDARDS AND POSTPONEMENT OF THE MINIMUM EMISSION STANDARDS TIMEFRAMES FOR ESKOM POWER STATIONS |date=23 August 2013 |url=https://cer.org.za/wp-content/uploads/2014/03/4_CER-submissions_Plan-of-Study_23-August-2013_final.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2013eskoms, author = {{Centre for Environmental Rights}}, title = {{ESKOM’S APPLICATION FOR EXEMPTION FROM MINIMUM EMISSION STANDARDS AND POSTPONEMENT OF THE MINIMUM EMISSION STANDARDS TIMEFRAMES FOR ESKOM POWER STATIONS}}, publisher = {Centre for Environmental Rights}, year = {2013}, month = aug, url = {https://cer.org.za/wp-content/uploads/2014/03/4_CER-submissions_Plan-of-Study_23-August-2013_final.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }