Comments on the series of Applications for Suspension of the Minimum Emissions Standards (MES) Compliance Timeframes for Various Eskom Coal-Fired Power Plants

This document provides a technical critique by consultant Dr. Ranajit (Ron) Sahu regarding Eskom's applications to suspend compliance timeframes for Minimum Emissions Standards (MES) at various coal-fired power plants. The author argues that Eskom's justifications for delays—including plant decommissioning, water scarcity, and capital costs—are untenable or substantially inflated, and suggests alternative technologies to achieve emission reductions.

• The author rejects Eskom's justification for delaying MES compliance based on planned decommissioning of plants like Arnot, noting that Eskom has not made a "legally binding commitment" to these dates, making it likely that plants will continue to operate.
• To address SO2 emissions in plants slated for decommissioning within five years, the author recommends Dry Sorbent Injection (DSI). DSI requires no water, can remove up to 50% of SO2, has capital costs less than 10% of wet FGD, and can be installed in under 12 months.
• The author characterizes Eskom's claims that the use of limestone, gypsum generation, and increased CO2 emissions make Flue Gas Desulfurization (FGD) inappropriate as "disingenuous" and "self-serving," noting that FGD is the global standard for SO2 removal.
• Eskom's estimated capital expenditure (CAPEX) for MES compliance is described as vastly overstated. Eskom estimated total CAPEX at over R187 billion in 2018 real terms, but the author's calculations based on Indian data suggest significantly lower costs: approximately 4.6 billion Rand for low NOx burners (compared to Eskom's 10-40 billion Rand) and just under 30 billion Rand for FGD (compared to Eskom's 140-170 billion Rand).
• The author identifies several emission control technologies and their typical installation timelines: Low NOx Burners (less than 12 months), DSI (12-18 months), SNCR (18 months or less), and FGD or SCR (approximately 36-40 months).

APA

Sahu, R. (. (n.d.). Comments on the series of Applications for Suspension of the Minimum Emissions Standards (MES) Compliance Timeframes for Various Eskom Coal-Fired Power Plants. Centre for Environmental Rights. https://cer.org.za/wp-content/uploads/2020/11/Annexure-1.pdf?x21779

Chicago

Sahu, Ranajit (Ron). Comments on the series of Applications for Suspension of the Minimum Emissions Standards (MES) Compliance Timeframes for Various Eskom Coal-Fired Power Plants. Centre for Environmental Rights, n.d. https://cer.org.za/wp-content/uploads/2020/11/Annexure-1.pdf?x21779.

Wikipedia

{{cite report |last1=Sahu |first1=Ranajit (Ron) |title=Comments on the series of Applications for Suspension of the Minimum Emissions Standards (MES) Compliance Timeframes for Various Eskom Coal-Fired Power Plants |publisher=Centre for Environmental Rights |url=https://cer.org.za/wp-content/uploads/2020/11/Annexure-1.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{sahundcomments, author = {Sahu, Ranajit (Ron)}, title = {{Comments on the series of Applications for Suspension of the Minimum Emissions Standards (MES) Compliance Timeframes for Various Eskom Coal-Fired Power Plants}}, institution = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2020/11/Annexure-1.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }