eskom-response-to-the-appeal-of-komati-power-station-ael-by-centre-for-environmental-rights-a515eaeb2159f7d2.pdf

This document is a formal response from Eskom to an appeal filed by the Centre for Environmental Rights (CER) regarding the Atmospheric Emission Licence (AEL) of the Komati Power Station. Eskom argues that the requested variations to the AEL would make the station's operation untenable from 2020 onwards and maintains that its application for a postponement of Minimum Emission Standards (MES) was lawful and technically justified.

• Eskom asserts that implementing the AEL variations requested by the Centre for Environmental Rights would result in Komati Power Station being unable to continue operating from 2020 or shortly thereafter. Eskom argues that the station's electricity production is currently essential to minimize South Africa's capacity shortfall.
• Eskom provided several justifications for requesting a 5-year postponement of certain Minimum Emission Standards (MES) for Komati Power Station, including the station's age and expected decommissioning between 2024 and 2028. They argue that installing upgraded technology is not feasible due to long project lead times and that reducing particulate emissions would result in at most a 1% change in ambient PM levels.
• Eskom claims that the installation of flue gas desulphurisation (FGD) to reduce SO2 emissions is currently impossible because there is no additional water available in the catchment. Additional water is only expected to be available from 2024 at the earliest following the completion of the second phase of the Lesotho Highlands Transfer Scheme.
• Eskom disputes the claim that it did not indicate an inability to meet the MES during the setting process. The company states it made numerous submissions to the SABS Steering Committee Working Groups, the Director-General of the Department of Environmental Affairs on 24 August 2009, and the Parliamentary Portfolio Committee on Water and Environmental Affairs in April 2013 regarding the challenges of compliance.
• Regarding air quality in the Highveld Priority Area (HPA), Eskom states that Komati is a relatively small contributor to emissions. In 2014/15, the station accounted for 5.4% of PM emissions, 1.7% of SO2 emissions, and 3% of NOx emissions emitted by Eskom's power stations in the HPA.
• Eskom argues that the requirement to provide a decommissioning plan at this stage is premature and theoretical, as the decision to decommission must be made holistically by considering the station's value to the national electricity supply against environmental impacts.
• Eskom agrees that the Komati offset programme should be expressed in quantitative terms with firm timeframes, proposing that these be included in an offsets implementation plan to be submitted by 31 March 2016.

APA

Centre for Environmental Rights (n.d.). eskom-response-to-the-appeal-of-komati-power-station-ael-by-centre-for-environmental-rights-a515eaeb2159f7d2.pdf. https://cer.org.za/wp-content/uploads/2014/06/Eskom-response-to-the-appeal-of-Komati-Power-Station-AEL-by-Centre-for-Environmental-Rights.pdf?x21779

Chicago

Centre for Environmental Rights. eskom-response-to-the-appeal-of-komati-power-station-ael-by-centre-for-environmental-rights-a515eaeb2159f7d2.pdf. n.d. https://cer.org.za/wp-content/uploads/2014/06/Eskom-response-to-the-appeal-of-Komati-Power-Station-AEL-by-Centre-for-Environmental-Rights.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=eskom-response-to-the-appeal-of-komati-power-station-ael-by-centre-for-environmental-rights-a515eaeb2159f7d2.pdf |url=https://cer.org.za/wp-content/uploads/2014/06/Eskom-response-to-the-appeal-of-Komati-Power-Station-AEL-by-Centre-for-Environmental-Rights.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsndeskomresponsetotheappealofkomatipowerstationaelbycentreforenvironmentalrightsa515eaeb2159f7d2pdf, author = {{Centre for Environmental Rights}}, title = {{eskom-response-to-the-appeal-of-komati-power-station-ael-by-centre-for-environmental-rights-a515eaeb2159f7d2.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/06/Eskom-response-to-the-appeal-of-Komati-Power-Station-AEL-by-Centre-for-Environmental-Rights.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }