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

The Centre for Environmental Rights (CER) submitted objections to the Final Integrated Water Use Licence Application (IWULA) for KiPower's proposed 600 MW coal-fired power station in Delmas, Mpumalanga. The CER and expert reviewers argue the application is fatally flawed, citing incorrect legal classifications of water use, insufficient groundwater baseline data, failure to address public concerns, and a lack of adequate monitoring and mitigation strategies. They recommend the application be rejected.

• The Centre for Environmental Rights (CER) argues that the Final Integrated Water Use Licence Application (IWULA) for KiPower's proposed 600 MW coal-fired power station is "inadequate and fatally flawed in material respects" and should be refused.
• The IWULA is criticized for failing to properly identify and describe water uses under the National Water Act, 1998. Specifically, it incorrectly classifies the removal of contaminated water from an excavated pit as a section 21(a) water use and incorrectly identifies activities within 500m of a wetland boundary as water uses under section 21(c) or 21(i).
• The document highlights a failure to provide sufficient baseline data on groundwater. It notes that the claim that groundwater quality is "good" is not scientifically based and is contradicted by the known contamination of water in the project's pit.
• The IWULA is accused of failing to adequately address public participation. It reportedly does not bring water-related concerns raised by interested and affected parties to the attention of the Department of Water and Sanitation, nor does it quantify or mitigate impacts on other water users.
• The report identifies significant gaps in the proposed monitoring and mitigation plans, including a lack of groundwater monitoring methodologies (relying only on "grab samples"), a lack of water quantity monitoring, and a failure to investigate the adverse effects of proposed mitigation measures.
• The CER notes that KiPower does not appear to accept responsibility for impacts from previous mining activities, treating the project as a "rehabilitation" while failing to address the 1999 Regulations on Use of Water for Mining and Related Activities.
• The IWULA is criticized for its heavy reliance on the Environmental Impact Assessment (EIA) and Environmental Management Programme (EMPr) rather than being a standalone document, which the CER claims inherits the flaws of those previous documents.

APA

Centre for Environmental Rights (2015). Comments on the Final 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-C-CER-gW-KiPower-Final-WULA-Objections.pdf?x21779

Chicago

Centre for Environmental Rights. Comments on the Final Integrated Water Use Licence Application Report for KiPower’s proposed construction of a 600 Megawatt (MW) Independent Power Producer Coal-fired Power Station. 2015. https://cer.org.za/wp-content/uploads/2017/09/Annexure-C-CER-gW-KiPower-Final-WULA-Objections.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=Comments on the Final Integrated Water Use Licence Application Report for KiPower’s proposed construction of a 600 Megawatt (MW) Independent Power Producer Coal-fired Power Station |date=24 March 2015 |url=https://cer.org.za/wp-content/uploads/2017/09/Annexure-C-CER-gW-KiPower-Final-WULA-Objections.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2015comments, author = {{Centre for Environmental Rights}}, title = {{Comments on the Final Integrated Water Use Licence Application Report for KiPower’s proposed construction of a 600 Megawatt (MW) Independent Power Producer Coal-fired Power Station}}, publisher = {Centre for Environmental Rights}, year = {2015}, month = mar, url = {https://cer.org.za/wp-content/uploads/2017/09/Annexure-C-CER-gW-KiPower-Final-WULA-Objections.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }