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

The document argues that Eskom's justifications for delaying emissions compliance—including plant decommissioning, water scarcity, and high costs—are untenable. The author contends that Eskom's capital expenditure estimates for air pollution controls are substantially inflated compared to similar projects in India and suggests alternative, lower-cost technologies like Dry Sorbent Injection (DSI) and Selective Non-catalytic Reduction (SNCR) to achieve emissions reductions.

• The author argues that Eskom's justification for delaying compliance based on the decommissioning of plants like Arnot is invalid because Eskom has not provided a "legally binding commitment to the supposed decommissioning date."
• To address SO2 emissions at plants slated for decommissioning within five years, the author recommends Dry Sorbent Injection (DSI), which requires no water, can remove up to 50% of SO2, and has capital costs less than 10% of wet Flue Gas Desulfurization (FGD).
• The author claims Eskom's estimated capital expenditure (CAPEX) for full MES compliance, cited as greater than R187 billion in 2018 real terms, is "vastly overstated" and lacks technical backup.
• Comparing Eskom's figures to 2018 data from India, the author estimates the cost of low NOx burners for Eskom's fleet at approximately 4.6 billion Rand, whereas Eskom's estimate ranged from 10-40 billion Rand, suggesting an inflation factor of 2 to 8.
• The author estimates that total FGD costs for eight specific Eskom plants (Matla, Duvha, Tutuka, Lethabo, Matimba, Kendal, Majuba, and Medupi) would be just under 30 billion Rand, significantly lower than Eskom's estimate of 140-170 billion Rand.
• The document outlines typical installation timeframes for various controls: fabric filter retrofits (12-18 months), low NOx burners (less than 12 months), SNCR (18 months or less), and FGD (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} }