SUPPLEMENTAL EXPERT REPORT OF DR. RANAJIT (RON) SAHU EVALUATING THE UPDATED AIR QUALITY IMPACT ASSESSMENT FOR THE PROPOSED LEPHALALE COAL MINE

Dr. Ranajit Sahu's expert report concludes that the Updated Air Quality Impact Assessment for the proposed Lephalale Coal Mine confirms that particulate matter emissions will exceed national health standards even with mitigation. He criticizes the assessment for using flawed US EPA methodologies, lacking data on Total Suspended Particulates, and using an unrealistic 'average' truck weight for emissions modeling.

• The Updated AQIA confirms that particulate matter (PM) emissions from the proposed Lephalale Mine will significantly exceed national standards and pose health risks, even with maximum efficiency mitigation measures. Specifically, PM2.5 24-hour average concentrations are predicted to exceed the national daily standard of 40μg/m3 up to approximately 8 km from the mine footprint, and annual average concentrations are predicted to exceed the national standard of 20μg/m3 within the footprint and up to 1 km to the west.
• Dr. Sahu argues that the Fourth Respondent's Answering Affidavit ignores the Updated AQIA's conclusions regarding adverse PM impacts and contains false claims. These include the false assertion that the Updated AQIA uses multiple air monitoring stations when it only uses data from the Lephalale station, and the claim that US EPA AP-42 inventory data is reliable, despite US EPA cautions to the contrary.
• The Updated AQIA's adoption of South African values for silt content of roads and moisture content of exposed ground, ROM coal, and overburden is noted as an improvement over US values, but Dr. Sahu states this change will actually increase predicted PM emissions and result in greater exceedances.
• The Updated AQIA is criticized for continuing to use a flawed methodology from the original 2017 AQIA, including the use of poorly-rated US EPA AP-42 emission factors and a lack of practical engineering design or operational details to support the assumed mitigation efficiency values.
• The Updated AQIA is described as incomplete and deficient because it lacks information on Total Suspended Particulates (TSP), which is the appropriate parameter for assessing compliance with National Dust Fall standards.
• Dr. Sahu identifies a weakness in the Updated AQIA's analysis of haul trucks on unpaved roads, noting that the use of an 'average' truck weight is illogical and should instead be replaced by separate calculations for fully loaded and empty trucks to better assess PM generation.

APA

Sahu, R. (. (2024). SUPPLEMENTAL EXPERT REPORT OF DR. RANAJIT (RON) SAHU EVALUATING THE UPDATED AIR QUALITY IMPACT ASSESSMENT FOR THE PROPOSED LEPHALALE COAL MINE. Centre for Environmental Rights. https://cer.org.za/wp-content/uploads/2024/10/Reply-to-Minister-with-annexures.pdf?x21779

Chicago

Sahu, Ranajit (Ron). SUPPLEMENTAL EXPERT REPORT OF DR. RANAJIT (RON) SAHU EVALUATING THE UPDATED AIR QUALITY IMPACT ASSESSMENT FOR THE PROPOSED LEPHALALE COAL MINE. Centre for Environmental Rights, 2024. https://cer.org.za/wp-content/uploads/2024/10/Reply-to-Minister-with-annexures.pdf?x21779.

Wikipedia

{{cite report |last1=Sahu |first1=Ranajit (Ron) |title=SUPPLEMENTAL EXPERT REPORT OF DR. RANAJIT (RON) SAHU EVALUATING THE UPDATED AIR QUALITY IMPACT ASSESSMENT FOR THE PROPOSED LEPHALALE COAL MINE |publisher=Centre for Environmental Rights |date=26 August 2024 |url=https://cer.org.za/wp-content/uploads/2024/10/Reply-to-Minister-with-annexures.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{sahu2024supplemental, author = {Sahu, Ranajit (Ron)}, title = {{SUPPLEMENTAL EXPERT REPORT OF DR. RANAJIT (RON) SAHU EVALUATING THE UPDATED AIR QUALITY IMPACT ASSESSMENT FOR THE PROPOSED LEPHALALE COAL MINE}}, institution = {Centre for Environmental Rights}, year = {2024}, month = aug, url = {https://cer.org.za/wp-content/uploads/2024/10/Reply-to-Minister-with-annexures.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }