annexure-g_submission-to-the-parliament-portfolio-committee-on-water-and-dea-april-2013-1-200121e7f260bef7.pdf

In a submission to the Parliament Portfolio Committee on Water and Environmental Affairs dated 12 April 2013, Eskom expresses concerns that full compliance with the Minimum Emission Standards (MES) for Listed Activities under the National Environmental Management: Air Quality Act, 2004, would threaten energy security and increase electricity tariffs. While supporting the act in general, Eskom argues that the standards ignore local scientific evidence and resource constraints, specifically regarding water availability and capital costs.

• Eskom argues that the Minimum Emission Standards (MES) were developed based on international practice without sufficient consideration of South Africa's local environment, scientific studies, or the link between emission standards and ambient air quality. The company claims that its emissions have minimal effects on receiving environments due to tall stacks that effectively disperse pollutants, and that poor air quality in South Africa is primarily caused by domestic combustion and indoor air quality rather than power station emissions.
• Full compliance with the MES presents several critical resource and operational constraints for Eskom. Water scarcity in the Highveld region makes the operation of Flue Gas Desulphurisation (FGD) impossible at all stations until the second phase of the Lesotho Highlands project is online, as FGD triples water consumption for dry-cooled stations. Additionally, the required retrofits for 87 existing units and 6 units at Medupi would require outages of up to 130 days per unit, which could lead to load shedding or electricity shortages before 2020 due to a lack of spare capacity.
• The financial and environmental costs of compliance are substantial. Eskom estimates that full fleet compliance would cost at least R170 billion in 2012 real terms, which would impact electricity tariffs. Environmentally, Eskom notes that FGD processes produce carbon dioxide both directly as a by-product and indirectly through reduced efficiency, creating a trade-off between reduced SO2 emissions and increased CO2 emissions contributing to global warming.
• Eskom identifies specific technical and regulatory gaps in the MES. It requests a 'grandfathering clause' to exempt older plants based on their remaining life and resource availability. Furthermore, it notes that the requirement for continuous emission monitoring (CEM) systems to be audited by a SANAS accredited laboratory every two years is currently impossible to meet because no such accredited laboratories for CEM exist in South Africa. Eskom also states that the 48-hour maximum duration for start-up is unattainable for many of its stations due to the design of the installed technology.

APA

Centre for Environmental Rights (n.d.). annexure-g_submission-to-the-parliament-portfolio-committee-on-water-and-dea-april-2013-1-200121e7f260bef7.pdf. https://cer.org.za/wp-content/uploads/2014/06/Annexure-G_Submission-to-the-parliament-portfolio-committee-on-water-and-DEA-April-2013-1.pdf?x21779

Chicago

Centre for Environmental Rights. annexure-g_submission-to-the-parliament-portfolio-committee-on-water-and-dea-april-2013-1-200121e7f260bef7.pdf. n.d. https://cer.org.za/wp-content/uploads/2014/06/Annexure-G_Submission-to-the-parliament-portfolio-committee-on-water-and-DEA-April-2013-1.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=annexure-g_submission-to-the-parliament-portfolio-committee-on-water-and-dea-april-2013-1-200121e7f260bef7.pdf |url=https://cer.org.za/wp-content/uploads/2014/06/Annexure-G_Submission-to-the-parliament-portfolio-committee-on-water-and-DEA-April-2013-1.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsndannexuregsubmissiontotheparliamentportfoliocommitteeonwateranddeaapril20131200121e7f260bef7pdf, author = {{Centre for Environmental Rights}}, title = {{annexure-g\_submission-to-the-parliament-portfolio-committee-on-water-and-dea-april-2013-1-200121e7f260bef7.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/06/Annexure-G_Submission-to-the-parliament-portfolio-committee-on-water-and-DEA-April-2013-1.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }