kriel-public-participation_annexure-vi-response-to-the-centre-for-environmental-rights-presentation-8761f9643fa29d09.pdf

This document is a formal response from Eskom to representations made by the Centre for Environmental Rights (CER) regarding Eskom's application to vary the Atmospheric Emission Licence (AEL) for the Kriel Power Station. Eskom argues that the variation is necessary to avoid power station shutdowns and subsequent load-shedding, asserting that Kriel's emissions do not significantly contribute to ambient particulate matter (PM) levels compared to surface sources.

• Eskom distinguishes between its November 2013 variation request for Kriel's AEL and its broader application for the postponement of Minimum Emission Standards (MES) compliance timeframes. The Kriel variation request specifically addresses the particulate emission limit from the time of application until 1 April 2015, whereas the postponement application concerns emission limits from 7 April 2015 onwards for a 5-year period.
• Eskom contends that Kriel Power Station is not a primary driver of ambient particulate matter (PM) levels in the Highveld Priority Area. Based on dispersion modelling and ambient monitoring in Kriel town, Eskom claims that surface sources, particularly domestic fires used for cooking and heating in the evening and morning, are the main contributors to PM concentrations, and that reducing Kriel's emissions to less than 50 mg/Nm³ would not noticeably improve ambient air quality.
• Eskom denies the CER's allegation that it is seeking to increase emissions. Instead, Eskom states it is seeking a licence that reflects the station's actual operational capabilities, as Kriel cannot consistently meet the current 125 mg/Nm³ limit due to its age, the quality of coal received, and frequent failures of electrostatic precipitator fields or SO₂ plants.
• Eskom disputes the CER's cost and timeline estimates for retrofitting Kriel with a fabric filter plant. Eskom argues that Kriel's units (500 MW each) are significantly larger than those at Hendrina (200 MW each) and that some casings must be rebuilt, justifying a six-year timeline to retrofit six units. Eskom also calculates the equivalent cost for Kriel at R2.16 billion, contrasting this with the CER's R750 million estimate by accounting for inflation and exchange rate shifts from 1995 to 2017.
• Eskom claims that failing to vary the AEL would force the de-loading or shutdown of Kriel, resulting in a loss of between 1500 MW and 2400 MW, which would lead to load-shedding and negative economic consequences for South Africa.
• Eskom outlines a retrofit schedule starting from the end of 2017 or start of 2018, with one unit retrofitted per year, aiming for all units to achieve emission levels below 50 mg/Nm³ by 2023.

APA

Centre for Environmental Rights (n.d.). kriel-public-participation_annexure-vi-response-to-the-centre-for-environmental-rights-presentation-8761f9643fa29d09.pdf. https://cer.org.za/wp-content/uploads/2014/03/Kriel-Public-Participation_Annexure-VI-Response-to-the-Centre-for-Environmental-Rights-Presentation.pdf?x21779

Chicago

Centre for Environmental Rights. kriel-public-participation_annexure-vi-response-to-the-centre-for-environmental-rights-presentation-8761f9643fa29d09.pdf. n.d. https://cer.org.za/wp-content/uploads/2014/03/Kriel-Public-Participation_Annexure-VI-Response-to-the-Centre-for-Environmental-Rights-Presentation.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=kriel-public-participation_annexure-vi-response-to-the-centre-for-environmental-rights-presentation-8761f9643fa29d09.pdf |url=https://cer.org.za/wp-content/uploads/2014/03/Kriel-Public-Participation_Annexure-VI-Response-to-the-Centre-for-Environmental-Rights-Presentation.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsndkrielpublicparticipationannexureviresponsetothecentreforenvironmentalrightspresentation8761f9643fa29d09pdf, author = {{Centre for Environmental Rights}}, title = {{kriel-public-participation\_annexure-vi-response-to-the-centre-for-environmental-rights-presentation-8761f9643fa29d09.pdf}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2014/03/Kriel-Public-Participation_Annexure-VI-Response-to-the-Centre-for-Environmental-Rights-Presentation.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }