khanyisa-affidavit-1-7ec7e1042a7ad55f.pdf

This document is an affidavit submitted by groundWork, a non-profit environmental justice organisation, to the National Energy Regulator of South Africa (NERSA). It presents supplementary objections to the license application by ACWA Power Khanyisa Thermal Power Station (RF) (Pty) Limited to operate the Khanyisa coal-fired power plant. groundWork argues that the project is unnecessary due to excess energy capacity, would violate constitutional rights to a healthy environment, and poses severe risks to the air quality of the Highveld Priority Area and the water resources of the Olifants River catchment.

• The Khanyisa power station is proposed for eMalahleni, Mpumalanga, located within the Highveld Priority Area (HPA), which has been in non-compliance with National Ambient Air Quality Standards (NAAQS) since its declaration in 2007.
• Research from the Council for Scientific and Industrial Research (CSIR) and Meridian Economics indicates that new coal-fired capacity is not required to meet South Africa's energy demand and is more expensive than renewable energy. Specifically, Khanyisa's electricity is estimated at R1.03 per KWh, compared to 62c per KWh for solar PV and wind.
• The project's Environmental Authorisation (EA) is under judicial review because it failed to conduct a comprehensive climate change impact assessment (CCIA), which is required following the Thabametsi judgment.
• The proposed coal ash dump for Khanyisa is situated on a rehabilitated open-cast mine with underground voids, creating a high risk of liner failure and rapid pollution transport into the Olifants River aquifer.
• The project's water use license (WUL) is disputed, with claims that the coal ash production rate was underestimated by approximately one-half compared to US circulating fluidised bed plants (0.36 tonnes/MWh vs 0.76 tonnes/MWh).
• Licensing the plant would allegedly violate Section 24 of the South African Constitution, as it would exacerbate air pollution in the HPA and contribute significant greenhouse gas emissions, potentially breaching Paris Agreement commitments.
• groundWork objects to the procedural fairness of NERSA's hearings, citing the failure to hold hearings in the local areas where the plants are based and the lack of timely information regarding procedural rules.
• The project's capacity was increased from 450MW to 600MW, but the Provisional Atmospheric Emission Licence (PAEL) transfer from Anglo Operations (Pty) Ltd is disputed because it reflects the original 450MW design.

APA

Centre for Environmental Rights (n.d.). khanyisa-affidavit-1-7ec7e1042a7ad55f.pdf. https://cer.org.za/wp-content/uploads/2018/03/Khanyisa-Affidavit-1.pdf?x21779

Chicago

Centre for Environmental Rights. khanyisa-affidavit-1-7ec7e1042a7ad55f.pdf. n.d. https://cer.org.za/wp-content/uploads/2018/03/Khanyisa-Affidavit-1.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=khanyisa-affidavit-1-7ec7e1042a7ad55f.pdf |url=https://cer.org.za/wp-content/uploads/2018/03/Khanyisa-Affidavit-1.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsndkhanyisaaffidavit17ec7e1042a7ad55fpdf, author = {{Centre for Environmental Rights}}, title = {{khanyisa-affidavit-1-7ec7e1042a7ad55f.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2018/03/Khanyisa-Affidavit-1.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }