Review of a Report Providing Health Impact Assessment and Cost-Benefit Analysis (CBA) of Eskom activities

This document is an independent review by Dr Michael Holland and Dr Joseph Spadaro of a health impact assessment and cost-benefit analysis (CBA) conducted for the South African power utility, Eskom. The reviewers conclude that the Eskom report contains significant methodological errors and biases that lead to a substantial underestimation of the health benefits of pollution controls. They calculate that the benefits of action would actually exceed costs by a factor of 5 or more, which reverses the conclusions of the original Eskom CBA.

• The Eskom report's pollutant modelling is inadequate because it relies on short-range modelling (up to 66 km), which fails to capture a major part of the impacts from high stack sources like coal-fired power plants. This approach biases the results toward a significant underestimation of impacts, particularly for secondary pollutants.
• The process for selecting response functions in the Eskom report is flawed. By not quantifying against the pollutant with the strongest association with the effect under examination, the analysis underestimates impacts; correcting this would more than double the estimate of impact.
• The Eskom report uses an interval-based approach to link pollutant concentrations with response functions, which the reviewers state is non-conservative and removes part of the exposure from calculations. This could lead to an underestimation of impacts by up to 50%.
• The use of a discount rate of 8.5% in the Eskom CBA is significantly higher than rates used in other socio-economic assessments, which biases the results toward an underestimation of economic damage and undermines the rights of future citizens.
• The Eskom analysis is limited to adult mortality, ignoring childhood mortality and morbidity (illness through the life-course). The reviewers estimate that including these additional health costs would add approximately 10% to 20% to the monetised total of mortality effects.
• The reviewers identify a lack of transparency and data in the Eskom report, noting that key results such as change in emissions for each power plant over time, attributable deaths by scenario, and population-weighted change in exposure were not provided.
• By accounting for the identified biases—including geographic range restrictions, non-continuous response functions, flawed function selection, and the omission of non-mortality effects—the reviewers calculate that the benefits of pollution controls would exceed costs by a factor of 5 or more, reversing the Eskom CBA's conclusions.

APA

Holland, M., & Spadaro, J. (2019). Review of a Report Providing Health Impact Assessment and Cost-Benefit Analysis (CBA) of Eskom activities. Centre for Environmental Rights. https://cer.org.za/wp-content/uploads/2020/08/Annexure-4.pdf?x21779

Chicago

Holland, Michael, and Joseph Spadaro. Review of a Report Providing Health Impact Assessment and Cost-Benefit Analysis (CBA) of Eskom activities. Centre for Environmental Rights, 2019. https://cer.org.za/wp-content/uploads/2020/08/Annexure-4.pdf?x21779.

Wikipedia

{{cite report |last1=Holland |first1=Michael |last2=Spadaro |first2=Joseph |title=Review of a Report Providing Health Impact Assessment and Cost-Benefit Analysis (CBA) of Eskom activities |publisher=Centre for Environmental Rights |date=14 February 2019 |url=https://cer.org.za/wp-content/uploads/2020/08/Annexure-4.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{holland2019review, author = {Holland, Michael and Spadaro, Joseph}, title = {{Review of a Report Providing Health Impact Assessment and Cost-Benefit Analysis (CBA) of Eskom activities}}, institution = {Centre for Environmental Rights}, year = {2019}, month = feb, url = {https://cer.org.za/wp-content/uploads/2020/08/Annexure-4.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }