OBJECTIONS TO THE VARIATION OF THE ATMOSPHERIC EMISSION LICENCE FOR ESKOM’S DUVHA POWER STATION

The Centre for Environmental Rights, representing various community and environmental groups, submitted formal objections on 14 February 2014 against Eskom's application to vary the Atmospheric Emission Licence (AEL) for the Duvha Power Station. The objections center on the potential for increased particulate matter (PM) emissions, flawed environmental modelling, and the contradiction of the Highveld Priority Area's air quality goals.

• The Centre for Environmental Rights objects to Eskom's request to increase PM emission limits for Duvha Power Station units 1-3 to 300mg/Nm3 and units 4-6 to 600mg/Nm3 for 111 days per year until 1 April 2015. The objection notes that Eskom claims a sulphur tank leak requires a 21-day repair period, yet seeks a much longer grace period per unit.
• The document asserts that granting the variation would exacerbate poor air quality in the Highveld Priority Area (HPA), where power generation is a major contributor to pollutants. Specifically, power generation is cited as contributing 12% of PM10, 73% of NOX, and 82% of SO2 emissions in the HPA.
• The objectors claim Eskom's atmospheric impact modelling is flawed and underestimates the impact on ambient air quality. They argue that Eskom's Atmospheric Impact Report (AIR) for Duvha fails to validate modelled concentrations against actual measurements and models the station in isolation from other surrounding power stations.
• The submission highlights significant health risks, stating that the Duvha application alone (at current rates) was estimated to cause 180 premature deaths per year. It further argues that Eskom's claim that power station emissions do not harm human health is contradicted by local and international research.
• The document alleges that Eskom has a history of systemic non-compliance with environmental legislation, citing the 2011-12 National Environmental Compliance and Enforcement Report which identifies Eskom as the organ of state with the highest rate of non-compliance.
• The objectors criticize the public participation process, arguing that the 15 working days provided for comment on the Duvha variation was unreasonable, especially given that stakeholders were simultaneously reviewing 81 other technical documents related to minimum emission standards (MES) postponements.

APA

Centre for Environmental Rights (2014). OBJECTIONS TO THE VARIATION OF THE ATMOSPHERIC EMISSION LICENCE FOR ESKOM’S DUVHA POWER STATION. https://cer.org.za/wp-content/uploads/2014/03/CER-Objection-to-Variation-of-Duvha-AEL-14-Feb-2014_final.pdf?x21779

Chicago

Centre for Environmental Rights. OBJECTIONS TO THE VARIATION OF THE ATMOSPHERIC EMISSION LICENCE FOR ESKOM’S DUVHA POWER STATION. 2014. https://cer.org.za/wp-content/uploads/2014/03/CER-Objection-to-Variation-of-Duvha-AEL-14-Feb-2014_final.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=OBJECTIONS TO THE VARIATION OF THE ATMOSPHERIC EMISSION LICENCE FOR ESKOM’S DUVHA POWER STATION |date=14 February 2014 |url=https://cer.org.za/wp-content/uploads/2014/03/CER-Objection-to-Variation-of-Duvha-AEL-14-Feb-2014_final.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2014objections, author = {{Centre for Environmental Rights}}, title = {{OBJECTIONS TO THE VARIATION OF THE ATMOSPHERIC EMISSION LICENCE FOR ESKOM’S DUVHA POWER STATION}}, publisher = {Centre for Environmental Rights}, year = {2014}, month = feb, url = {https://cer.org.za/wp-content/uploads/2014/03/CER-Objection-to-Variation-of-Duvha-AEL-14-Feb-2014_final.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }