COMMENTS ON THE REVISED ATMOSPHERIC IMPACT REPORT AND ATMOSPHERIC EMISSION LICENCE APPLICATION FOR THE PROPOSED IPP THABAMETSI COAL-FIRED POWER STATION

The Centre for Environmental Rights (CER), on behalf of Earthlife Africa and groundWork, submitted comments on September 20, 2018, objecting to the Atmospheric Emission Licence (AEL) application for the proposed Thabametsi coal-fired power station. The CER argues that the project should be refused because it is located in an air quality priority area already in non-compliance with National Ambient Air Quality Standards (NAAQS) and is predicted to cause further non-compliance, specifically regarding sulphur dioxide (SO2). The CER claims the Atmospheric Impact Report (AIR) is fatally flawed due to gross miscalculations of emissions, missing modelling data, and a failure to adequately assess cumulative and health impacts.

• The proposed project is located in the Waterberg Bojanala Air Quality Priority Area, which is already in non-compliance with National Ambient Air Quality Standards (NAAQS), with exceedances of PM2.5, PM10, and O3 recorded in Thabazimbi, Mokopane, and Xanadu.
• The revised Atmospheric Impact Report (AIR) predicts that the Thabametsi project will cause further non-compliance with NAAQS for sulphur dioxide (SO2) in 2023, particularly in areas south of the Medupi and Matimba Power Stations, before the predicted completion of Medupi's flue gas desulphurisation (FGD) retrofit in 2025.
• The CER alleges gross miscalculations in the AIR's emission modelling, stating that the report used emission concentrations significantly lower than the Minimum Emission Standards (MES) limits. For example, the AIR assumed a PM10 concentration of 0.7 mg/Nm3 instead of the MES limit of 50 mg/Nm3, a difference of 70 times.
• The AEL application is criticized for omitting crucial modelling data required by the DEA Code of Practice and the Air Dispersion Modelling Regulations, including input and output files for models, pre-processors, post-processors, digital terrain files, and plot files.
• The CER argues that the cumulative impact assessment is flawed because it excludes 'low-level' fugitive emissions from coal and lime stockpiles, ash dumps, and mine activities, resulting in a scenario where cumulative pollutant levels appear lower than those of the Thabametsi project alone.
• The health risk study included in the application is described as fatally flawed and outdated, as it dates from 2013 and fails to provide a quantitative assessment of health impacts, relying instead on the incorrect assumption that compliance with NAAQS equates to an acceptable health risk.
• The CER highlights the failure to account for emissions from surrounding mines, specifically the proposed Thabametsi Coal Mine and the existing Grootegeluk mine, including the risk of spontaneous combustion and coal fires which generate significant ground-level pollutants.

APA

Centre for Environmental Rights (2018). COMMENTS ON THE REVISED ATMOSPHERIC IMPACT REPORT AND ATMOSPHERIC EMISSION LICENCE APPLICATION FOR THE PROPOSED IPP THABAMETSI COAL-FIRED POWER STATION. https://cer.org.za/wp-content/uploads/2019/08/CER-ELA-gW-comments-on-revised-Thabametsi-AELA-20-9-18.docx.pdf?x21779

Chicago

Centre for Environmental Rights. COMMENTS ON THE REVISED ATMOSPHERIC IMPACT REPORT AND ATMOSPHERIC EMISSION LICENCE APPLICATION FOR THE PROPOSED IPP THABAMETSI COAL-FIRED POWER STATION. 2018. https://cer.org.za/wp-content/uploads/2019/08/CER-ELA-gW-comments-on-revised-Thabametsi-AELA-20-9-18.docx.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=COMMENTS ON THE REVISED ATMOSPHERIC IMPACT REPORT AND ATMOSPHERIC EMISSION LICENCE APPLICATION FOR THE PROPOSED IPP THABAMETSI COAL-FIRED POWER STATION |date=20 September 2018 |url=https://cer.org.za/wp-content/uploads/2019/08/CER-ELA-gW-comments-on-revised-Thabametsi-AELA-20-9-18.docx.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2018comments, author = {{Centre for Environmental Rights}}, title = {{COMMENTS ON THE REVISED ATMOSPHERIC IMPACT REPORT AND ATMOSPHERIC EMISSION LICENCE APPLICATION FOR THE PROPOSED IPP THABAMETSI COAL-FIRED POWER STATION}}, publisher = {Centre for Environmental Rights}, year = {2018}, month = sep, url = {https://cer.org.za/wp-content/uploads/2019/08/CER-ELA-gW-comments-on-revised-Thabametsi-AELA-20-9-18.docx.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }