SUBMISSIONS ON DRAFT CLIMATE CHANGE IMPACT ASSESSMENT REPORT FOR THABAMETSI IPP COAL-FIRED POWER STATION

The Centre for Environmental Rights, acting for Earthlife Africa Johannesburg, submitted comments on the draft Climate Change Impact Assessment (CCIA) and Palaeontological Impact Assessment (PIA) for the proposed Thabametsi coal-fired power station. The submission argues that the draft CCIA significantly underestimates greenhouse gas emissions, ignores the social cost of carbon, and fails to adequately address severe water scarcity risks in the Lephalale area. The authors contend that the project is not in the national interest due to existing excess energy capacity and that the most appropriate recommendation is a 'no go option' to avoid irreversible environmental and social harm.

• The draft CCIA's greenhouse gas (GHG) emissions calculations are significantly underestimated because they only account for carbon dioxide (CO2) and omit nitrous oxide (N2O) and methane (CH4). The submission notes that N2O emissions from the proposed circulating fluidised bed (CFB) unit can be 43 times greater than those from a pulverised fuel boiler, potentially representing about 14% of total GHG emissions.
• The project fails to consider the social cost of carbon, which includes external costs to human health, property damage from flood risk, and agricultural productivity. Using a US Environmental Protection Agency protocol, the submission estimates the social cost of the Thabametsi power station could exceed USD 12 billion per year by 2030.
• There is a critical failure to assess how the project will exacerbate climate change impacts for local communities and the environment in Lephalale, particularly regarding water scarcity. While the Climate Resilience Assessment (CRA) identifies water shortages as a high risk to the project's viability, it does not analyze how the plant's own water demands will further deprive local farmers and residents in a 'heavily stressed' river basin.
• The project's long-term feasibility is threatened by water availability risks and the potential for the plant to become a 'stranded asset'. The submission highlights that the proposed Mokolo Crocodile Water Augmentation Project Phase 2 (MCWAP2), which the plant relies on, has not yet commenced its EIA scoping phase, creating significant uncertainty.
• The submission argues that the project is not necessary for national energy security, citing that Eskom had 11,000 MW of excess capacity daily as of May 2016 and that renewable energy alternatives are more affordable and efficient.
• The draft CCIA contradicts previous claims that the plant would use 'cleaner' technology. The assessment concludes that the plant's emissions intensity is relatively high compared to other plants and does not represent an improvement over the current South African grid intensity, partly because the chosen technology is designed for low-cost, lower-quality coal rather than maximum emission reduction.
• The Palaeontological Impact Assessment (PIA) identifies a risk of 'irreversible damage' to fossil materials during construction. While the probability is rated low to medium, the severity is potentially 'extremely high' for Cenozoic deposits due to their scientific significance.

APA

Centre for Environmental Rights (2017). SUBMISSIONS ON DRAFT CLIMATE CHANGE IMPACT ASSESSMENT REPORT FOR THABAMETSI IPP COAL-FIRED POWER STATION. https://cer.org.za/wp-content/uploads/2016/07/Annexure-1-ELA-Comments-on-draft-CCIA-PIA-27-2-17.pdf?x21779

Chicago

Centre for Environmental Rights. SUBMISSIONS ON DRAFT CLIMATE CHANGE IMPACT ASSESSMENT REPORT FOR THABAMETSI IPP COAL-FIRED POWER STATION. 2017. https://cer.org.za/wp-content/uploads/2016/07/Annexure-1-ELA-Comments-on-draft-CCIA-PIA-27-2-17.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=SUBMISSIONS ON DRAFT CLIMATE CHANGE IMPACT ASSESSMENT REPORT FOR THABAMETSI IPP COAL-FIRED POWER STATION |date=27 February 2017 |url=https://cer.org.za/wp-content/uploads/2016/07/Annexure-1-ELA-Comments-on-draft-CCIA-PIA-27-2-17.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2017submissions, author = {{Centre for Environmental Rights}}, title = {{SUBMISSIONS ON DRAFT CLIMATE CHANGE IMPACT ASSESSMENT REPORT FOR THABAMETSI IPP COAL-FIRED POWER STATION}}, publisher = {Centre for Environmental Rights}, year = {2017}, month = feb, url = {https://cer.org.za/wp-content/uploads/2016/07/Annexure-1-ELA-Comments-on-draft-CCIA-PIA-27-2-17.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }