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, led by the Centre for Environmental Rights (CER), formally objects to Eskom's application for the suspension, postponement, or alternative limits of Minimum Emission Standards (MES) for 10 coal-fired power stations. The submission argues that Eskom fails to meet the legal prerequisites of the 2017 National Framework for Air Quality Management, specifically regarding National Ambient Air Quality Standards (NAAQS) compliance and the prevention of direct adverse health impacts.

• The submission argues that Eskom's applications for postponement, suspension, or alternative limits are legally impermissible because the power stations are located in areas that do not comply with National Ambient Air Quality Standards (NAAQS). Specifically, the Vaal Triangle Airshed Priority Area (VTAPA) and the Highveld Priority Area (HPA) remain in non-compliance, which is a mandatory condition for such applications under the 2017 Framework.
• A health assessment by Lauri Myllyvirta and the Greenpeace Global Air Pollution Unit estimates that air pollutant emissions from Eskom's coal-fired plants will cause 2,400 premature deaths per year once Medupi and Kusile are fully operational. Furthermore, if Eskom's applications for postponed compliance are granted, it is projected that approximately 23,000 premature deaths will occur over time.
• The document claims that Eskom's 'Health impact focused cost benefit analyses' (CBA) is fatally flawed. Criticisms include the exclusion of approximately 70% of South Africa's population from the study, the use of an inadequate 60km modelling range for secondary particles, and the use of a high discounting rate (8.5%) that reduces the projected benefits of emission reductions.
• 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 power stations. Some exceedances were significantly higher than the limits, such as PM levels reaching 600 mg/Nm3 at Kriel, compared to a MES of 100 mg/Nm3.
• The submission asserts that Eskom's decommissioning schedule is too broad and lacks the detail required by the 2017 Framework. It fails to provide specific dates for Environmental Impact Assessment (EIA) processes, financial provisions for rehabilitation of coal ash dumps, or transparent social and labour closure plans for affected staff.
• The document disputes Eskom's claim that installing abatement technology takes 12 or more years. It provides benchmarks from the US, where pollution controls like Flue Gas Desulphurisation (FGD) are typically installed within 50 months, and notes that plants in Europe, China, and Japan have successfully implemented similar or stricter controls despite similar plant ages.
• Eskom's air quality offset programme, which targets household emissions in communities like KwaZamokuhle and Ezamokuhle, is described as ineffective. The submission argues that offsetting tall stack emissions with household interventions does not resolve regional non-compliance with NAAQS and that pilot projects have faced poor workmanship and unfulfilled promises.
• The submission criticizes a November 2018 amendment to the List of Activities that doubled the permissible SO2 emissions for existing solid-fuel combustion installations from 500mg/Nm3 to 1000mg/Nm3, calling the amendment unlawful due to a lack of public participation.

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} }