SUBMISSIONS ON THE BACKGROUND INFORMATION DOCUMENT (BID) FOR ESKOMS SECOND POSTPONEMENT APPLICATION IN RESPECT OF THE 2015 MINIMUM EMISSION STANDARDS (MES) FOR TUTUKA POWER STATION

The Life After Coal campaign and the Highveld Environmental Justice Alliance Network argue that Eskom's application for a second postponement of Minimum Emission Standards (MES) at the Tutuka Power Station is legally impermissible. They contend that because Tutuka is located in the Highveld Priority Area (HPA), where ambient air quality does not comply with National Ambient Air Quality Standards (NAAQS), no postponement can be granted under the existing regulatory framework. The submission further alleges that the Background Information Document (BID) is defective and misleading, omitting critical health data and failing to justify delays in installing abatement technology. The authors assert that 'rolling postponements' are equivalent to illegal exemptions and demand the rejection of the application based on constitutional environmental rights and the National Environmental Management: Air Quality Act.

• The Background Information Document (BID) is described as defective and misleading because it fails to mention that Tutuka is in the HPA, omits the specific pollutants and timeframes for which postponement is sought, and provides relaxed emission limits without comparing them to the legally required MES.
• Eskom's use of "rolling postponements" is characterized as an illegal practice equivalent to an exemption from MES compliance, which is not permitted under the National Environmental Management: Air Quality Act (AQA).
• The proposed Atmospheric Impact Report (AIR) and Atmospheric Dispersion Modelling (ADM) are deemed insufficient because they intend to exclude detailed health and environmental risk assessments and only model emissions from Tutuka rather than accounting for cumulative impacts from other nearby sources.
• Research indicates significant health and economic costs associated with Tutuka Power Station, including an estimated 192 equivalent attributable deaths annually and an economic loss of R2.4 billion per year due to premature deaths, hospital admissions, and lost working days.

APA

Centre for Environmental Rights (2018). SUBMISSIONS ON THE BACKGROUND INFORMATION DOCUMENT (BID) FOR ESKOMS SECOND POSTPONEMENT APPLICATION IN RESPECT OF THE 2015 MINIMUM EMISSION STANDARDS (MES) FOR TUTUKA POWER STATION. https://cer.org.za/wp-content/uploads/2018/02/LAC-and-HEJN-comment-on-Tutuka-MES-postponement-BID-19.02.18.pdf?x21779

Chicago

Centre for Environmental Rights. SUBMISSIONS ON THE BACKGROUND INFORMATION DOCUMENT (BID) FOR ESKOMS SECOND POSTPONEMENT APPLICATION IN RESPECT OF THE 2015 MINIMUM EMISSION STANDARDS (MES) FOR TUTUKA POWER STATION. 2018. https://cer.org.za/wp-content/uploads/2018/02/LAC-and-HEJN-comment-on-Tutuka-MES-postponement-BID-19.02.18.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=SUBMISSIONS ON THE BACKGROUND INFORMATION DOCUMENT (BID) FOR ESKOMS SECOND POSTPONEMENT APPLICATION IN RESPECT OF THE 2015 MINIMUM EMISSION STANDARDS (MES) FOR TUTUKA POWER STATION |date=19 February 2018 |url=https://cer.org.za/wp-content/uploads/2018/02/LAC-and-HEJN-comment-on-Tutuka-MES-postponement-BID-19.02.18.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2018submissions, author = {{Centre for Environmental Rights}}, title = {{SUBMISSIONS ON THE BACKGROUND INFORMATION DOCUMENT (BID) FOR ESKOMS SECOND POSTPONEMENT APPLICATION IN RESPECT OF THE 2015 MINIMUM EMISSION STANDARDS (MES) FOR TUTUKA POWER STATION}}, publisher = {Centre for Environmental Rights}, year = {2018}, month = feb, url = {https://cer.org.za/wp-content/uploads/2018/02/LAC-and-HEJN-comment-on-Tutuka-MES-postponement-BID-19.02.18.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }