Comments on the Integrated Water Use Licence Application Report for KiPower’s proposed construction of a 600 Megawatt (MW) Independent Power Producer Coal-fired Power Station

This document consists of a formal submission by the Centre for Environmental Rights (CER) and an accompanying independent peer review by Carin Bosman Sustainable Solutions (CBSS). It critiques the Integrated Water Use Licence Application (IWULA) Report prepared by Jones and Wagner for KiPower's proposed 600 MW coal-fired power station in Mpumalanga, South Africa. The CER and CBSS conclude that the IWULA is 'Inadequate' due to significant procedural and substantive failures, including the absence of a practical Integrated Water and Waste Management Plan (IWWMP) Action Plan and a failure to adequately assess impacts on groundwater and other water users.

• The IWULA Report is graded as 'Inadequate' because it fails to provide a complete baseline of information, lacks a description of the socio-economic environment, fails to determine the correct types of water use authorisations, and ignores public input when formulating water management objectives.
• A critical omission in the application is the absence of an Integrated Water and Waste Management Plan (IWWMP) Action Plan, which is a requirement for WULAs that impact water quality. The report merely states the plan will be included in the submission to the Department of Water Affairs, making it unavailable for public scrutiny.
• The IWULA fails to meet the substantive requirements of the National Water Act (NWA) and the guidelines prescribed by the Department of Water and Sanitation (DWS) regarding the prevention of water pollution and judicious water management.
• There are severe gaps in the biophysical baseline data, specifically regarding groundwater. The report lacks site-specific information on groundwater conditions, baseline pollution levels at the proposed Ash Disposal Facility (ADF) and Power Station sites, and the acid-generating potential of materials in existing pits.
• The application is legally flawed in its treatment of Existing Lawful Uses (ELUs) and General Authorisations (GAs). Because the project is on a brownfields site with existing infrastructure, the failure to address the current authorisation status and compliance of these facilities makes it impossible to determine if activities are authorised as ELUs.
• The IWULA is criticized for attempting to minimize or avoid public participation. While it describes the consultation process, it fails to record or extract specific concerns raised by interested and affected parties regarding impacts on water or other water users.
• The proposed water monitoring programme is deemed insufficient because it lacks coordinates for monitoring locations, specifies no methodologies for groundwater monitoring, and provides no programme for monitoring water quantity.
• The report contains technical deficiencies, including illegible water balance figures and a lack of specific discharge points or volumes for Section 21(f) water uses.
• The CER warns that the IWULA is susceptible to judicial review under the Promotion of Administrative Justice Act, 2000, and recommends that authorities reject the reports or refuse the applications until deficiencies are rectified.

APA

Centre for Environmental Rights (2014). Comments on the Integrated Water Use Licence Application Report for KiPower’s proposed construction of a 600 Megawatt (MW) Independent Power Producer Coal-fired Power Station. https://cer.org.za/wp-content/uploads/2017/09/Annexure-B-CER-gW-KiPower-WULA-Objections.pdf?x21779

Chicago

Centre for Environmental Rights. Comments on the Integrated Water Use Licence Application Report for KiPower’s proposed construction of a 600 Megawatt (MW) Independent Power Producer Coal-fired Power Station. 2014. https://cer.org.za/wp-content/uploads/2017/09/Annexure-B-CER-gW-KiPower-WULA-Objections.pdf?x21779.

Wikipedia

{{cite report |author=Centre for Environmental Rights |title=Comments on the Integrated Water Use Licence Application Report for KiPower’s proposed construction of a 600 Megawatt (MW) Independent Power Producer Coal-fired Power Station |date=2 September 2014 |url=https://cer.org.za/wp-content/uploads/2017/09/Annexure-B-CER-gW-KiPower-WULA-Objections.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centreforenvironmentalrights2014comments, author = {{Centre for Environmental Rights}}, title = {{Comments on the Integrated Water Use Licence Application Report for KiPower’s proposed construction of a 600 Megawatt (MW) Independent Power Producer Coal-fired Power Station}}, institution = {Centre for Environmental Rights}, year = {2014}, month = sep, url = {https://cer.org.za/wp-content/uploads/2017/09/Annexure-B-CER-gW-KiPower-WULA-Objections.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }