REPLY TO ESKOM’S ISSUES AND RESPONSE REPORT APPENDIX F TO THE PUBLIC PARTICIPATION PROCESS REPORT DATED FEBRUARY 2014

The Centre for Environmental Rights (CER), representing several community and environmental groups, submitted a formal reply on 24 March 2014 challenging Eskom's applications for postponement from the Minimum Emission Standards (MES). The CER disputes Eskom's claims that its power stations have a marginal impact on air quality and health, arguing that Eskom's Atmospheric Impact Reports (AIRs) are anecdotal, use insufficient modeling domains, and fail to quantify the health risks associated with secondary PM2.5 formation and mercury emissions.

• The CER disputes Eskom's claim that its power stations contribute marginally to ambient air quality, arguing that Eskom's Atmospheric Impact Reports (AIRs) rely on an "anecdotal narrative" rather than quantitative modeling. The CER recommends that Eskom use the CALPUFF model to quantify how many exceedances of National Ambient Air Quality Standards (NAAQS) could be avoided if power station emissions were eliminated.
• The CER argues that Eskom's air quality modeling is fundamentally flawed because the domain size is too small, excluding the majority of population exposure and health risks. The CER asserts that a proper health impact assessment requires a modeling domain covering at least 1,000km from the power plants.
• The CER highlights a significant omission in Eskom's reports regarding secondary PM2.5 formation. While Eskom claims its contribution to PM10 is marginal, the CER argues that short-range modeling ignores the primary impact of power plants on ambient air quality, which is the formation of secondary PM2.5.
• The CER challenges Eskom's dismissal of health risk assessments, noting that the FRIDGE Study estimated that seven operational coal-fired Eskom power stations were responsible for 51% of all respiratory hospital admissions in the Mpumalanga Highveld. The CER further references an estimate of 20,000 premature deaths annually linked to Eskom's activities.
• The CER criticizes Eskom for failing to provide detailed measurement data on mercury emissions in its applications and reports. The CER argues that the failure to quantify the effect of requested postponements on mercury emissions is "unacceptable" given the associated health and environmental issues.
• The CER disputes Eskom's claim that the costs of compliance with the MES outweigh the benefits, stating that Eskom has failed to conduct a comparable assessment of the benefits, specifically the avoided health impacts.

APA

Centre for Environmental Rights (2014). REPLY TO ESKOM’S ISSUES AND RESPONSE REPORT APPENDIX F TO THE PUBLIC PARTICIPATION PROCESS REPORT DATED FEBRUARY 2014. https://cer.org.za/wp-content/uploads/2014/03/CER-reply-to-Eskoms-Issues-Response-Report_24-March-2014_final.pdf?x21779

Chicago

Centre for Environmental Rights. REPLY TO ESKOM’S ISSUES AND RESPONSE REPORT APPENDIX F TO THE PUBLIC PARTICIPATION PROCESS REPORT DATED FEBRUARY 2014. 2014. https://cer.org.za/wp-content/uploads/2014/03/CER-reply-to-Eskoms-Issues-Response-Report_24-March-2014_final.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=REPLY TO ESKOM’S ISSUES AND RESPONSE REPORT APPENDIX F TO THE PUBLIC PARTICIPATION PROCESS REPORT DATED FEBRUARY 2014 |date=24 March 2014 |url=https://cer.org.za/wp-content/uploads/2014/03/CER-reply-to-Eskoms-Issues-Response-Report_24-March-2014_final.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2014reply, author = {{Centre for Environmental Rights}}, title = {{REPLY TO ESKOM’S ISSUES AND RESPONSE REPORT APPENDIX F TO THE PUBLIC PARTICIPATION PROCESS REPORT DATED FEBRUARY 2014}}, publisher = {Centre for Environmental Rights}, year = {2014}, month = mar, url = {https://cer.org.za/wp-content/uploads/2014/03/CER-reply-to-Eskoms-Issues-Response-Report_24-March-2014_final.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }