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

The document argues that Eskom's applications for emission standard postponements and exemptions are legally invalid because ambient air quality standards (AAQS) are already exceeded in the affected priority areas. It highlights significant health risks, particularly from SO2 and mercury, and criticizes Eskom for failing to consider feasible alternatives such as renewable energy or decommissioning worst-performing plants. The submission also references a World Bank Inspection Panel report on the Medupi Power Plant, which found inadequate consideration of environmental principles, water scarcity risks, and cumulative health impacts.

• Postponement applications for minimum emission standards (MES) are legally impermissible under the Framework for Air Quality Management if ambient air quality standards (AAQS) in the area are not in compliance.
• The majority of Eskom's power stations are located in declared priority areas where air quality is already problematic and AAQS are frequently exceeded, specifically for PM10 and PM2.5 in the Highveld and Vaal Triangle.
• In the Vaal Triangle Airshed Priority Area (VTAPA), power generation is a dominant source of pollution, contributing approximately 86% of total estimated SO2 emissions and 74% of total estimated oxides of nitrogen (NOx).
• In the Highveld Priority Area (HPA), power generation contributes 82% of SO2 and 73% of NOx emissions, and is estimated to be the primary driver of hospital admissions in Mpumalanga with a 51% contribution.
• Eskom claims that full compliance with MES would cost approximately R210 billion, but the document argues that this cost could be mitigated by investing in renewables, decommissioning poor-performing plants, or using higher-grade coal.
• A University of Pretoria study suggests that the external costs of the Kusile plant are so high that investing only 30% of those costs into renewables could develop at least 500% of Kusile's proposed power generation capacity.
• The document disputes Eskom's claim that emissions do not harm human health, noting that South Africa's AAQS for particulate matter (PM) are substantially lower than World Health Organisation (WHO) recommendations.
• The World Bank Inspection Panel found that the Medupi Power Plant's Environmental Impact Report (EIR) failed to adequately consider the National Environmental Management (NEM) Principles and underestimated air quality impacts.
• The Medupi plant faces significant risks regarding water scarcity, as the operation of its wet flue gas desulphurisation (FGD) technology depends on the timely delivery of Phase 2 of the Mokolo-Crocodile (West) Water Augmentation Project (MCWAP).
• The World Bank Inspection Panel concluded that Medupi's greenhouse gas (GHG) emissions are significant and that claims about the project enabling a low carbon trajectory were overly optimistic.

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/2014/02/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. 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 |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}}, 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} }