SUBMISSIONS ON FINAL SCOPE OF WORK REPORT FOR THABAMETSI IPP COAL-FIRED POWER STATION DEA REF 14/12/16/3/3/3/40

The Centre for Environmental Rights (CER), acting for Earthlife Africa Johannesburg, submitted comments to the Department of Environmental Affairs (DEA) regarding the Final Scope of Work Report (FSR) for the Thabametsi coal-fired power station. The CER argues that the FSR is inadequate, particularly concerning the Climate Change Impact Assessment (CCIA), and requests that the DEA either reject the report or require significant amendments to align it with the South African Constitution and the National Environmental Management Act (NEMA).

• The CER contends that the Final Scope of Work Report (FSR) is materially inadequate because it fails to incorporate substantive changes suggested in the draft report and maintains a climate change impact assessment (CCIA) scope that is too narrow and inconsistent with global practice.
• The CER asserts that a comprehensive CCIA for the Thabametsi project must include assessments of indirect or full life-cycle emissions, cumulative emissions, the social cost of carbon, and the project's resilience to climate change, including the risk of becoming a stranded asset.
• The document highlights that South Africa's ratification of the Paris Agreement and its Nationally Determined Contribution (NDC) create legal and environmental obligations that may be inconsistent with a new coal-fired power station intended to operate for at least 40 years.
• The CER criticizes the project developer's rejection of international best practices for the CCIA, arguing that since South Africa lacks specific guidelines for coal-fired power station climate assessments, foreign laws and guidelines should serve as a benchmark.
• The CER identifies a failure in the FSR to address how climate change will affect water availability in the Mokolo and Crocodile West catchments, which are critical for the project's operation and long-term feasibility.
• The CER notes a factual error in the FSR regarding the project developer, stating that the environmental authorisation was amended on 26 August 2016 to change the holder from Newshelf 1282 (Pty) Limited to Thabametsi Power Company (Pty) Limited.

APA

Centre for Environmental Rights (2016). SUBMISSIONS ON FINAL SCOPE OF WORK REPORT FOR THABAMETSI IPP COAL-FIRED POWER STATION DEA REF 14/12/16/3/3/3/40. https://cer.org.za/wp-content/uploads/2016/07/Comments-on-Final-Thabametsi-Scoping-Report-10-11-16-003.pdf?x21779

Chicago

Centre for Environmental Rights. SUBMISSIONS ON FINAL SCOPE OF WORK REPORT FOR THABAMETSI IPP COAL-FIRED POWER STATION DEA REF 14/12/16/3/3/3/40. 2016. https://cer.org.za/wp-content/uploads/2016/07/Comments-on-Final-Thabametsi-Scoping-Report-10-11-16-003.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=SUBMISSIONS ON FINAL SCOPE OF WORK REPORT FOR THABAMETSI IPP COAL-FIRED POWER STATION DEA REF 14/12/16/3/3/3/40 |date=10 November 2016 |url=https://cer.org.za/wp-content/uploads/2016/07/Comments-on-Final-Thabametsi-Scoping-Report-10-11-16-003.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2016submissions, author = {{Centre for Environmental Rights}}, title = {{SUBMISSIONS ON FINAL SCOPE OF WORK REPORT FOR THABAMETSI IPP COAL-FIRED POWER STATION DEA REF 14/12/16/3/3/3/40}}, publisher = {Centre for Environmental Rights}, year = {2016}, month = nov, url = {https://cer.org.za/wp-content/uploads/2016/07/Comments-on-Final-Thabametsi-Scoping-Report-10-11-16-003.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }