record-5.1-to-5.2-c788b6939cbc1e02.pdf

This briefing document, submitted to the Eskom Board Sustainability Committee on 2 August 2013, outlines the company's inability to fully comply with South Africa's National Emission Standards without jeopardizing its sustainability. It proposes a strategy of partial compliance through targeted retrofits, legal applications for exemptions and postponements, and requests to continue operating non-compliant power stations while implementing remedies.

• Eskom asserts that full compliance with the 2020 Minimum Emission Standards is not feasible due to severe financial, operational, and environmental impacts. Estimated capital expenditure (CAPEX) for full retrofits is approximately R199 billion in 2012 real terms, with annual operating expenses (OPEX) of around R6 billion. Such a move would increase electricity tariffs by more than 25%, increase water consumption by 20% (an additional 70 million cubic metres per annum), and result in 150-day outages for all units before April 2020.
• To balance environmental requirements with energy security, Eskom recommends a phased approach to achieve 60% compliance with the Minimum Emission Standards. This plan involves a CAPEX investment of R72 billion in 2012 real terms (R58 billion excluding the Medupi FGD retrofit) and includes fabric filter plant retrofits at up to 6 full and 2 half stations, De-NOx retrofits at the 4 highest emitting stations, and flue gas desulphurisation at Medupi and potentially Kendal.
• Eskom identifies current illegal operations at Kriel, Matla, and Duvha power stations, where units cannot meet particulate (ash) emission limits set in their Atmospheric Emission Licences (AELs). Specifically, non-compliance is noted at Kriel (six units), Matla (one unit), and Duvha (up to three units). Eskom requested permission to continue operating these units while pursuing remedies such as refurbishments, repairs, and applications for more lenient emission limits.
• The Medupi Power Station faces commissioning delays because it cannot meet the CO2 emission limits of its provisional AEL and the supplied coal often fails to meet design specifications. Additionally, the provisional AEL does not cover the excess coal stockyard scheduled for use from 1 February 2014. Eskom proposed high-level political interventions with the Limpopo MEC to resolve an appeal lodged in July 2012.
• Eskom's legal strategy for non-compliance involves applying for 5-year postponements where standards can eventually be met, and full exemptions with more lenient limits where compliance is not feasible before decommissioning. The company intends to support these applications with an Atmospheric Impact Report, economic motivations, and a willingness to implement household emission offsets such as providing LPG or insulation.

APA

Centre for Environmental Rights (n.d.). record-5.1-to-5.2-c788b6939cbc1e02.pdf. https://cer.org.za/wp-content/uploads/2016/05/Record-5.1-to-5.2.pdf?x21779

Chicago

Centre for Environmental Rights. record-5.1-to-5.2-c788b6939cbc1e02.pdf. n.d. https://cer.org.za/wp-content/uploads/2016/05/Record-5.1-to-5.2.pdf?x21779.

Wikipedia

{{cite report |author=Centre for Environmental Rights |title=record-5.1-to-5.2-c788b6939cbc1e02.pdf |url=https://cer.org.za/wp-content/uploads/2016/05/Record-5.1-to-5.2.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centreforenvironmentalrightsndrecord51to52c788b6939cbc1e02pdf, author = {{Centre for Environmental Rights}}, title = {{record-5.1-to-5.2-c788b6939cbc1e02.pdf}}, institution = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2016/05/Record-5.1-to-5.2.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }