annexure-6-nersa-khanyisa-covering-letter-and-objection-62e14486936e5cd7.pdf

The GroundWork Trust submitted a formal objection to the National Energy Regulator of South Africa (NERSA) regarding an electricity generation permit application by ACWA Power Khanyisa Thermal Power Station (RF) (Pty) Limited. GroundWork argues that the proposed coal-fired power plant is unnecessary, economically unviable, and would cause severe environmental and public health damage in an area already suffering from critical air pollution.

• The proposed Khanyisa thermal coal-fired power plant is planned for a 600 megawatt (MW) capacity with four coal burning units, although the specific application to NERSA is for the operation of two units with a maximum generation capacity of 345.4 MW.
• The plant would be located in the eMalahleni Local Municipality within the Highveld Priority Area (HPA), a region designated in November 2007 because pollution levels exceeded ambient air quality standards due to numerous coal-fired power stations and open-cast mines.
• GroundWork asserts that the application is incomplete because it lacks critical environmental and health documentation, including the final environmental impact review (FEIR), air quality impact assessments, and health impact assessments.
• Significant portions of the application were redacted or withheld as confidential, including the Power Purchase Agreement, Financial Model and Assumptions Book, and Net Annual Cash Flows, which GroundWork claims hinders public scrutiny of the project's sustainability.
• The proposed plant would use subcritical Circulating Fluidized Bed (CFB) boilers with 35.5% efficiency, which GroundWork describes as outdated; they argue that ultra-supercritical CFB units could reach efficiencies in the low- to mid-40% range and reduce emissions by approximately 16%.
• The project's coal ash disposal plan is criticized as inadequate; analysis suggests the proposed landfill may only last 3.5 years—less than 10% of the plant's 40-year design life—due to waste volumes being six times higher than originally planned in the FEIR.
• The plant's location in the Upper Olifants River sub-catchment poses risks to a water system already facing a crisis due to acid mine drainage, with specific concerns that leachate from the ash dump could impact surface water resources.
• GroundWork argues that the project is based on an outdated 2010 Integrated Resource Plan (IRP) and a 2014 energy crisis that no longer exists, noting that Eskom had a surplus of 5,600MW at peak as of January 2017.
• Citing a CSIR study, the objection claims that a 70% renewable energy mix by 2040 would be 40% cheaper than new baseload coal and could save Rand 87 billion per year by 2040.

APA

Centre for Environmental Rights (n.d.). annexure-6-nersa-khanyisa-covering-letter-and-objection-62e14486936e5cd7.pdf. https://cer.org.za/wp-content/uploads/2016/07/Annexure-6-NERSA-Khanyisa-covering-Letter-and-objection.pdf?x21779

Chicago

Centre for Environmental Rights. annexure-6-nersa-khanyisa-covering-letter-and-objection-62e14486936e5cd7.pdf. n.d. https://cer.org.za/wp-content/uploads/2016/07/Annexure-6-NERSA-Khanyisa-covering-Letter-and-objection.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=annexure-6-nersa-khanyisa-covering-letter-and-objection-62e14486936e5cd7.pdf |url=https://cer.org.za/wp-content/uploads/2016/07/Annexure-6-NERSA-Khanyisa-covering-Letter-and-objection.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsndannexure6nersakhanyisacoveringletterandobjection62e14486936e5cd7pdf, author = {{Centre for Environmental Rights}}, title = {{annexure-6-nersa-khanyisa-covering-letter-and-objection-62e14486936e5cd7.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2016/07/Annexure-6-NERSA-Khanyisa-covering-Letter-and-objection.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }