SUBMISSIONS ON ESKOM’S APPLICATION FOR SUSPENSION, ALTERNATIVE LIMITS AND/OR POSTPONEMENT OF COMPLIANCE WITH THE MINIMUM EMISSION STANDARDS FOR 10 OF ITS COAL-FIRED POWER STATIONS

The Life After Coal campaign argues that Eskom's applications to delay or suspend compliance with Minimum Emission Standards (MES) are unlawful under the 2017 National Framework for Air Quality Management. The campaign asserts that the required condition for such applications—that the surrounding area be in compliance with National Ambient Air Quality Standards (NAAQS)—is not met in the Highveld Priority Area (HPA) or Vaal Triangle Airshed Priority Area (VTAPA). Furthermore, the document highlights severe health impacts, claiming that excess emissions could result in approximately 23,000 premature deaths. It criticizes Eskom's decommissioning schedules as vague and its air quality offset programs as ineffective, while providing international benchmarks to refute Eskom's claims that retrofitting older plants is infeasible.

• Eskom's applications for postponement, suspension, or alternative limits are legally impermissible because the Highveld Priority Area (HPA), Vaal Triangle Airshed Priority Area (VTAPA), and Waterberg-Bojanala Priority Area (WBPA) are not in compliance with National Ambient Air Quality Standards (NAAQS).
• Excess emissions resulting from the granting of Eskom's applications are projected to cause approximately 23,000 premature deaths over time, whereas full compliance with the MES would reduce the cumulative health impact by 40%.
• An assessment of Eskom's monthly emission reports from April 2016 to December 2017 found nearly 3,200 exceedances of daily Atmospheric Emission Licences (AEL) limits for particulate matter (PM), sulphur dioxide (SO2), and oxides of nitrogen (NOx) across 13 coal-fired power stations.
• Eskom's proposed decommissioning schedule is deemed insufficient and not 'detailed' or 'clear' as required by law, as it lacks specific process timelines, environmental impact assessment (EIA) start dates, and social and labour closure plans.
• The campaign disputes Eskom's claim that retrofitting older plants takes 12 or more years, citing US evidence where pollution controls like Flue Gas Desulphurisation (FGD) are typically installed within 50 months.
• Eskom's air quality offset program, intended to reduce household emissions, is described as ineffective and failing, with evidence from the KwaZamokuhle community showing poor workmanship and unfulfilled promises.
• The campaign argues that Eskom's use of a cost-benefit analysis (CBA) to justify non-compliance is legally baseless and that the CBA significantly underestimates health impacts by excluding 70% of the population and using flawed modelling.

APA

Centre for Environmental Rights (2019). SUBMISSIONS ON ESKOM’S APPLICATION FOR SUSPENSION, ALTERNATIVE LIMITS AND/OR POSTPONEMENT OF COMPLIANCE WITH THE MINIMUM EMISSION STANDARDS FOR 10 OF ITS COAL-FIRED POWER STATIONS. https://cer.org.za/wp-content/uploads/2023/02/Annexure-A3_Life-After-Coal-objections_February-2019.pdf?x21779

Chicago

Centre for Environmental Rights. SUBMISSIONS ON ESKOM’S APPLICATION FOR SUSPENSION, ALTERNATIVE LIMITS AND/OR POSTPONEMENT OF COMPLIANCE WITH THE MINIMUM EMISSION STANDARDS FOR 10 OF ITS COAL-FIRED POWER STATIONS. 2019. https://cer.org.za/wp-content/uploads/2023/02/Annexure-A3_Life-After-Coal-objections_February-2019.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=SUBMISSIONS ON ESKOM’S APPLICATION FOR SUSPENSION, ALTERNATIVE LIMITS AND/OR POSTPONEMENT OF COMPLIANCE WITH THE MINIMUM EMISSION STANDARDS FOR 10 OF ITS COAL-FIRED POWER STATIONS |date=4 February 2019 |url=https://cer.org.za/wp-content/uploads/2023/02/Annexure-A3_Life-After-Coal-objections_February-2019.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2019submissions, author = {{Centre for Environmental Rights}}, title = {{SUBMISSIONS ON ESKOM’S APPLICATION FOR SUSPENSION, ALTERNATIVE LIMITS AND/OR POSTPONEMENT OF COMPLIANCE WITH THE MINIMUM EMISSION STANDARDS FOR 10 OF ITS COAL-FIRED POWER STATIONS}}, publisher = {Centre for Environmental Rights}, year = {2019}, month = feb, url = {https://cer.org.za/wp-content/uploads/2023/02/Annexure-A3_Life-After-Coal-objections_February-2019.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }