record-6.1-to-6.2-b073b68dae94a8ee.pdf

This document is an executive summary and board submission from Eskom dated August 28, 2013, regarding compliance with South Africa's National Emission Standards and Atmospheric Emission Licences (AELs). It outlines the financial and operational impossibility of full compliance by 2020, proposes a partial compliance strategy, and requests permission to continue operating several power stations that are currently in breach of their emission limits.

• Eskom determined that full compliance with the 2020 Minimum Emission Standards is not feasible because it would jeopardize the company's sustainability. The primary constraints include a projected electricity tariff increase of more than 25%, the requirement for 150-day outages for all units before April 2020 (meaning 14% of the coal fleet would be offline at any time between 2017 and 2020), and a water deficit in the Vaal River catchment that would prevent the operation of flue gas desulphurisation (FGD) before 2022.
• The estimated capital expenditure (CAPEX) for full compliance with the 2020 limits is approximately R199 billion in 2012 real terms, with additional annual operating expenses (OPEX) of about R6 billion. In contrast, Eskom's proposed partial compliance approach—aiming for 60% compliance—would require a CAPEX of R72 billion in 2012 real terms (or R58 billion excluding the Medupi FGD retrofit) and an OPEX of R950 million.
• To achieve 60% compliance, Eskom proposed a phased retrofit program including fabric filter plant (FFP) retrofits at up to 6 full stations and 2 half stations, De-NOx retrofits at the 4 highest emitting stations, and flue gas desulphurisation (FGD) at Medupi and potentially Kendal.
• Eskom identified several power stations operating illegally due to non-compliance with particulate (ash) emission limits in their Atmospheric Emission Licences (AELs), specifically six units at Kriel Power Station, two units at Duvha Power Station, and occasionally one unit at Matla Power Station. The board was asked for permission to continue operating these units while seeking legal remedies, noting that if permission was not granted by the end of December 2013, at least 3000 MW (all units at Kriel) would need to be shut down.
• The proposed legal strategy for handling non-compliance involves applying for 5-year postponements for standards that can be met eventually, and full exemptions (with more lenient limits) for cases where compliance is not feasible before decommissioning. Eskom also planned to engage government departments, including the Department of Energy, Department of Water Affairs, NERSA, Department of Public Enterprises, and Department of Environmental Affairs.
• Full compliance with the 2020 standards would result in several negative environmental and operational externalities, including the release of over a million additional tons of CO2 due to the wet FGD process and the production of approximately 8.4 million tons of FGD by-products annually.

APA

Centre for Environmental Rights (n.d.). record-6.1-to-6.2-b073b68dae94a8ee.pdf. https://cer.org.za/wp-content/uploads/2016/05/Record-6.1-to-6.2.pdf?x21779

Chicago

Centre for Environmental Rights. record-6.1-to-6.2-b073b68dae94a8ee.pdf. n.d. https://cer.org.za/wp-content/uploads/2016/05/Record-6.1-to-6.2.pdf?x21779.

Wikipedia

{{cite report |author=Centre for Environmental Rights |title=record-6.1-to-6.2-b073b68dae94a8ee.pdf |url=https://cer.org.za/wp-content/uploads/2016/05/Record-6.1-to-6.2.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{centreforenvironmentalrightsndrecord61to62b073b68dae94a8eepdf, author = {{Centre for Environmental Rights}}, title = {{record-6.1-to-6.2-b073b68dae94a8ee.pdf}}, institution = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2016/05/Record-6.1-to-6.2.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }