ESKOM’S APPLICATION FOR EXEMPTION FROM MINIMUM EMISSION STANDARDS AND POSTPONEMENT OF THE MINIMUM EMISSION STANDARDS TIMEFRAMES FOR ESKOM POWER STATIONS COMMENTS ON THE BACKGROUND INFORMATION DOCUMENT

The Centre for Environmental Rights (CER), representing several community groups and NGOs, submitted comments on July 19, 2013, opposing Eskom's applications for exemptions and postponements regarding Minimum Emission Standards (MES). The CER argues that such applications are legally invalid because ambient air quality standards (AAQS) are already exceeded in the priority areas where most Eskom plants are located. The document highlights severe health risks, particularly from SO2 and mercury, and criticizes Eskom for failing to consider renewable energy alternatives or the decommissioning of worst-performing plants.

• Eskom's applications for postponement of MES compliance time-frames are argued to be legally invalid because the Framework for Air Quality Management requires that such applications only be considered if ambient air quality standards (AAQS) in the area are in compliance, which is not the case for the affected areas.
• The vast majority of Eskom's power stations are located in declared priority areas where air quality is already problematic. These include the Highveld Priority Area (HPA), the Vaal Triangle Airshed Priority Area (VTAPA), and the Waterberg Priority Area (WPA).
• In the Vaal Triangle Airshed Priority Area (VTAPA), power generation is a primary source of pollutants, contributing approximately 24% of fine PM10, 74% of oxides of nitrogen (NOx), and 86% of total SO2 emissions.
• In the Highveld Priority Area (HPA), power generation is a major contributor to emissions, accounting for 12% of PM10, 73% of NOx, and 82% of SO2. Power generation activities are estimated to be the primary driver of hospital admissions in Mpumalanga, contributing 51%.
• The CER disputes Eskom's claim that power station emissions do not harm human health, citing a University of Pretoria study that estimated the external public health costs of the Kusile plant between R182 million and R213 million.
• The document highlights the risk of mercury emissions from the coal-fired electricity sector in South Africa, estimated at 30-40 tonnes, and notes that the Minamata Convention on Mercury was agreed upon in January 2013 to limit such emissions.
• Eskom estimates that full compliance with MES would cost approximately R210 billion in capital costs. The CER argues that Eskom has not explained why it has rejected alternatives such as decommissioning worst-performing plants or investing in renewables.
• A University of Pretoria study suggests that the opportunity cost of the Kusile plant is significant; using only 30% of its external costs could potentially develop 500% of Kusile's proposed power generation capacity through renewables.
• A World Bank Inspection Panel report on the Medupi Power Plant found that the project's Environmental Impact Report (EIR) failed to adequately consider the National Environmental Management (NEM) Principles and underestimated air quality impacts.
• The World Bank Inspection Panel noted that without SO2 abatement (Flue Gas Desulphurisation - FGD), health risks for residents of Marapong and Onverwacht would be 'high' to 'medium high'. There are concerns that water scarcity may delay the implementation of wet FGD technology.

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 COMMENTS ON THE BACKGROUND INFORMATION DOCUMENT. https://cer.org.za/wp-content/uploads/2014/02/Annexure-3_CER-submissions_Eskom-BID_19-July-20131.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 COMMENTS ON THE BACKGROUND INFORMATION DOCUMENT. 2013. https://cer.org.za/wp-content/uploads/2014/02/Annexure-3_CER-submissions_Eskom-BID_19-July-20131.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 COMMENTS ON THE BACKGROUND INFORMATION DOCUMENT |date=19 July 2013 |url=https://cer.org.za/wp-content/uploads/2014/02/Annexure-3_CER-submissions_Eskom-BID_19-July-20131.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 COMMENTS ON THE BACKGROUND INFORMATION DOCUMENT}}, publisher = {Centre for Environmental Rights}, year = {2013}, month = jul, url = {https://cer.org.za/wp-content/uploads/2014/02/Annexure-3_CER-submissions_Eskom-BID_19-July-20131.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }