SUBMISSIONS ON THE BACKGROUND INFORMATION DOCUMENT (BID) FOR ESKOM’S APPLICATION FOR POSTPONEMENT OF THE MINIMUM EMISSION STANDARDS (MES) FOR 14 OF ITS COAL AND LIQUID FUEL-FIRED POWER STATIONS

The Centre for Environmental Rights (CER), acting as part of the Life After Coal campaign, submitted a formal objection to Eskom's application to postpone compliance with Minimum Emission Standards (MES) for 14 power stations. The submission argues that such postponements are legally impermissible because the power stations are located in priority areas where national ambient air quality standards (NAAQS) are not being met. The CER contends that the Background Information Document (BID) provided by Eskom is incomplete and misleading, and that the continued emissions cause severe health impacts and premature deaths in surrounding communities.

• The CER argues that Eskom's application for MES postponement is legally invalid because the Framework for Air Quality Management only allows postponements if "ambient air quality standards in the area are in compliance, and will remain in compliance even if the postponement is granted". Since 11 of the 14 stations are in the Highveld Priority Area (HPA) and one is in the Vaal Triangle Airshed Priority Area (VTAPA)—both of which are in non-compliance with NAAQS—the application should be denied.
• The submission claims that Eskom is seeking "rolling postponements" for sulphur dioxide (SO2) new plant MES for the majority of its stations, which the CER asserts are effectively illegal exemptions from the law.
• The CER asserts that the Background Information Document (BID) is defective and misleading because it fails to mention that the power stations are located in priority areas out of compliance with NAAQS and omits the relaxed Atmospheric Emission Licence (AEL) limits currently applied to the stations.
• An assessment of Eskom's monthly emissions reports from April 2016 to December 2017 for 14 coal-fired power stations revealed over 3,000 exceedances of daily average emission limits for particulate matter (PM), SO2, and NOx.
• The document cites a 2016 report by Dr Mike Holland estimating that PM2.5 emissions from Eskom's coal-fired power plants cause 2,239 deaths per year, including 157 from lung cancer, 1,110 from ischaemic heart disease, 719 from strokes, and 180 from lower respiratory infection.
• The CER highlights that Eskom's own 2006 studies acknowledged the health risks of its operations; one study on the Mpumalanga Highveld predicted that future emissions, including new and return-to-service stations, would be responsible for 617 non-accidental mortalities and 24,842 respiratory hospital admissions annually.
• The submission criticizes Eskom's proposed air quality modelling for being too narrow, as it only includes individual Eskom stations and ignores other major emission sources within a 100km radius, such as the Sasol Synfuels plant and various coal mining operations.
• The CER notes that South African SO2 existing plant MES are significantly weaker than international standards, being 17.5 times weaker than those in China, Germany, and the European Union, and nearly 6 times weaker than India's.
• The document states that power generation is a dominant source of pollution in the Highveld, accounting for 73% of all NOx and 82% of SO2 in the region.

APA

Centre for Environmental Rights (2018). SUBMISSIONS ON THE BACKGROUND INFORMATION DOCUMENT (BID) FOR ESKOM’S APPLICATION FOR POSTPONEMENT OF THE MINIMUM EMISSION STANDARDS (MES) FOR 14 OF ITS COAL AND LIQUID FUEL-FIRED POWER STATIONS. https://cer.org.za/wp-content/uploads/2018/09/LAC-MES-Postponement-Submissions-11-September-2018.pdf?x21779

Chicago

Centre for Environmental Rights. SUBMISSIONS ON THE BACKGROUND INFORMATION DOCUMENT (BID) FOR ESKOM’S APPLICATION FOR POSTPONEMENT OF THE MINIMUM EMISSION STANDARDS (MES) FOR 14 OF ITS COAL AND LIQUID FUEL-FIRED POWER STATIONS. 2018. https://cer.org.za/wp-content/uploads/2018/09/LAC-MES-Postponement-Submissions-11-September-2018.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=SUBMISSIONS ON THE BACKGROUND INFORMATION DOCUMENT (BID) FOR ESKOM’S APPLICATION FOR POSTPONEMENT OF THE MINIMUM EMISSION STANDARDS (MES) FOR 14 OF ITS COAL AND LIQUID FUEL-FIRED POWER STATIONS |date=11 September 2018 |url=https://cer.org.za/wp-content/uploads/2018/09/LAC-MES-Postponement-Submissions-11-September-2018.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 ESKOM’S APPLICATION FOR POSTPONEMENT OF THE MINIMUM EMISSION STANDARDS (MES) FOR 14 OF ITS COAL AND LIQUID FUEL-FIRED POWER STATIONS}}, publisher = {Centre for Environmental Rights}, year = {2018}, month = sep, url = {https://cer.org.za/wp-content/uploads/2018/09/LAC-MES-Postponement-Submissions-11-September-2018.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }