WRITTEN OBJECTIONS TO ESKOM’S APPLICATION FOR A ONCE-OFF SUSPENSION OF COMPLIANCE WITH THE NEW PLANT MINIMUM EMISSION STANDARDS AND VARIATION REQUEST FOR THE GROOTVLEI POWER STATION

The Centre for Environmental Rights (CER), acting as part of the Life After Coal campaign and other environmental justice networks, submitted written objections on July 30, 2020, against Eskom's application for a once-off suspension of compliance with New Plant Minimum Emission Standards (MES) and a variation request for the Grootvlei Power Station. The CER argues that the application is procedurally invalid, lacks a detailed decommissioning schedule, and unlawfully seeks to extend polluting activities beyond the station's end-of-life, thereby violating constitutional rights to a healthy environment.

• The CER objects to Eskom's application for Grootvlei Power Station on the grounds that it was submitted after the legally mandated deadline of 31 March 2019, making the piecemeal application invalid under the Listed Activities and 2017 Framework.
• Eskom's application seeks an alternative daily limit of 1100 mg/Nm3 for NOx and 3500 mg/Nm3 for SO2 from 1 April 2000 [sic] until a shutdown anticipated by 2028, and no later than 2030.
• The CER argues that Eskom's decommissioning schedule for Grootvlei is vague and fails to meet the requirement for a "detailed" and "clear" schedule, noting that the station's 50-year life decommissioning dates were originally scheduled for 2018-2020 in the Integrated Resource Plan for Electricity, 2019.
• The CER contends that granting the suspension would unlawfully extend polluting activities at Grootvlei beyond its 50-year end-of-life, which is particularly concerning as the station is located in the Highveld Priority Area, a region that does not comply with South Africa's National Ambient Air Quality Standards (NAAQS).
• The CER highlights a critical failure in the Atmospheric Impact Report, which stated it was not possible to satisfactorily address PM2.5 issues due to inconsistent and limited data from monitoring stations.
• The CER asserts that Eskom's approach to MES compliance violates Section 24 of the Constitution of the Republic of South Africa, 1996, which guarantees the right to an environment not harmful to health and well-being.
• Based on 2018 data, Eskom estimated that emissions from 13 of its coal-fired power stations would cause 320 additional premature mortality cases and R17.6 billion in baseline health costs annually, though the CER notes independent studies suggest these figures are higher.

APA

Centre for Environmental Rights (2020). WRITTEN OBJECTIONS TO ESKOM’S APPLICATION FOR A ONCE-OFF SUSPENSION OF COMPLIANCE WITH THE NEW PLANT MINIMUM EMISSION STANDARDS AND VARIATION REQUEST FOR THE GROOTVLEI POWER STATION. https://cer.org.za/wp-content/uploads/2020/08/LAC-submission_objections-to-Grootvlei-MES-suspension-application_30-July-2020.pdf?x21779

Chicago

Centre for Environmental Rights. WRITTEN OBJECTIONS TO ESKOM’S APPLICATION FOR A ONCE-OFF SUSPENSION OF COMPLIANCE WITH THE NEW PLANT MINIMUM EMISSION STANDARDS AND VARIATION REQUEST FOR THE GROOTVLEI POWER STATION. 2020. https://cer.org.za/wp-content/uploads/2020/08/LAC-submission_objections-to-Grootvlei-MES-suspension-application_30-July-2020.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=WRITTEN OBJECTIONS TO ESKOM’S APPLICATION FOR A ONCE-OFF SUSPENSION OF COMPLIANCE WITH THE NEW PLANT MINIMUM EMISSION STANDARDS AND VARIATION REQUEST FOR THE GROOTVLEI POWER STATION |date=30 July 2020 |url=https://cer.org.za/wp-content/uploads/2020/08/LAC-submission_objections-to-Grootvlei-MES-suspension-application_30-July-2020.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2020written, author = {{Centre for Environmental Rights}}, title = {{WRITTEN OBJECTIONS TO ESKOM’S APPLICATION FOR A ONCE-OFF SUSPENSION OF COMPLIANCE WITH THE NEW PLANT MINIMUM EMISSION STANDARDS AND VARIATION REQUEST FOR THE GROOTVLEI POWER STATION}}, publisher = {Centre for Environmental Rights}, year = {2020}, month = jul, url = {https://cer.org.za/wp-content/uploads/2020/08/LAC-submission_objections-to-Grootvlei-MES-suspension-application_30-July-2020.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }