annexure-d-eskom_s-comments-on-notice-of-intention-to-amend-the-list-of-activities-nemaqa-91d9e06058865dae.pdf

This document is a formal statement from Eskom Holdings SOC Limited submitted to the Department of Environmental Affairs on 22 June 2017. It provides comments and recommendations regarding the 'Notice of Intention to Amend the List of Activities which Result in Atmospheric Emission' under the National Environmental Management: Air Quality Act (39/2004). Eskom argues that the proposed emission standards lack comprehensive cost-benefit analysis and could lead to severe financial and operational burdens, potentially necessitating significant electricity tariff increases.

• Eskom asserts that the proposed draft regulations regarding new plant minimum emission standards would significantly increase compliance costs to between R 250 billion and R 300 billion, which would result in an electricity tariff increase of at least 7%.
• The company identifies several operational and environmental resource pressures resulting from compliance requirements by 2025, including a projected 20% increase in water usage (67 million cubic metres per annum), the need for 6.5 million tons of sorbent annually, and a reduction in coal fleet energy output by almost 2,255 GWh per annum.
• Eskom argues that emission standards for SO2 in the electricity sector were not informed by appropriate cost-benefit analysis (CBA). Citing a 2016 University of Pretoria dissertation, Eskom claims it is unlikely that the benefits of reducing SO2 emissions to the required standard outweigh the implementation costs.
• Eskom recommends that existing plants should only be required to comply with existing plant standards for SO2 until their final decommissioning, with the exception of Medupi, which is proceeding with a flue gas desulphurisation (FGD) retrofit project.
• The company reports progress on its air quality improvement programme, including the installation of fabric filter plants at Arnot, Duvha, Camden, Hendrina, Grootvlei, and Majuba between 1993 and 2010, and the completion of a retrofit at Grootvlei in October 2017.
• Eskom has implemented an air quality offset plan approved in September 2016 with a nominal cost exceeding R4 billion over nine years. This plan focuses on switching households in KwaZamokuhle, Ezamokuhle, Sharpeville/Vaal, and Marapong from coal and waste burning to electricity and LPG during 2018 and 2019.
• Eskom proposes amendments to the draft legislation's compliance timeframes, specifically suggesting that the 31 March 2025 deadline for postponements be extended by up to three years (to 2028) if an air quality improvement schedule is not completed by the original date.

APA

Centre for Environmental Rights (n.d.). annexure-d-eskom_s-comments-on-notice-of-intention-to-amend-the-list-of-activities-nemaqa-91d9e06058865dae.pdf. https://cer.org.za/wp-content/uploads/2023/02/Annexure-D-Eskom_s-comments-on-Notice-of-Intention-to-Amend-the-List-of-Activities-NEMAQA.pdf?x21779

Chicago

Centre for Environmental Rights. annexure-d-eskom_s-comments-on-notice-of-intention-to-amend-the-list-of-activities-nemaqa-91d9e06058865dae.pdf. n.d. https://cer.org.za/wp-content/uploads/2023/02/Annexure-D-Eskom_s-comments-on-Notice-of-Intention-to-Amend-the-List-of-Activities-NEMAQA.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=annexure-d-eskom_s-comments-on-notice-of-intention-to-amend-the-list-of-activities-nemaqa-91d9e06058865dae.pdf |url=https://cer.org.za/wp-content/uploads/2023/02/Annexure-D-Eskom_s-comments-on-Notice-of-Intention-to-Amend-the-List-of-Activities-NEMAQA.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsndannexuredeskomscommentsonnoticeofintentiontoamendthelistofactivitiesnemaqa91d9e06058865daepdf, author = {{Centre for Environmental Rights}}, title = {{annexure-d-eskom\_s-comments-on-notice-of-intention-to-amend-the-list-of-activities-nemaqa-91d9e06058865dae.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2023/02/Annexure-D-Eskom_s-comments-on-Notice-of-Intention-to-Amend-the-List-of-Activities-NEMAQA.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }