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An assessment of new coal plants in South Africa’s electricity future
This research report assesses the impact of including two coal-fired independent power producer (IPP) projects—Thabametsi and Khanyisa—in South Africa's electricity system from 2022 to 2052. Using the South African Times Model (SATIM), the study finds that these plants are not necessary to meet demand and would increase both total system costs and greenhouse gas emissions across all analyzed scenarios, potentially offsetting national energy efficiency and carbon tax mitigation efforts.
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Document type: Research paper
RELEVANT INFORMATION ON THE COAL INDEPENDENT POWER PRODUCERS (IPPS)
The Centre for Environmental Rights (CER) submitted a statement to the Portfolio Committee on Environmental Affairs on May 22, 2018, opposing the approval of coal-fired Independent Power Producers (IPPs), specifically Thabametsi and Khanyisa. The CER argues that these projects are unnecessary, economically damaging, and environmentally catastrophic, citing high greenhouse gas emissions, water scarcity, and air pollution in priority areas.
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Document type: Statement
COMMENTS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT AND WASTE MANAGEMENT LICENCE VARIATION APPLICATION FOR THE PROPOSED RETROFITTING OF A FLUE GAS DESULPHURISATION SYSTEM AT MEDUPI POWER STATION, LEPHALALE, LIMPOPO PROVINCE
The Centre for Environmental Rights (CER), acting for groundWork and Earthlife Africa, submitted comments on April 19, 2018, regarding the Draft Environmental Impact Report (DEIR) and Waste Management Licence (WML) Variation Application for the Flue Gas Desulphurisation (FGD) Retrofit Project at Medupi Power Station. The CER argues that Eskom has adopted a 'piecemeal approach' to the environmental impact assessment (EIA), deferring critical issues such as water security, waste minimisation, and health impacts to separate processes to 'fast track' the project. The submission specifically challenges the rejection of inlet gas cooler technology, which could reduce water consumption by approximately 30%, and criticizes the plan to co-dispose of gypsum and ash, which would destroy the commercial value of the gypsum.
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Document type: Statement
WRITTEN SUBMISSIONS ON THE CLIMATE CHANGE MITIGATION POLICIES AND MEASURES FINAL DRAFT REPORT
The Centre for Environmental Rights (CER) provides written submissions on the March 2018 Final Draft Report of Climate Change Mitigation Policies and Measures (PAMs). The CER supports the examination of policy effectiveness but identifies several gaps, including the need for better alignment between various government climate projects, the exclusion of certain greenhouse gases and externalities in socio-economic analyses, and a lack of rationale for prioritizing coal-to-liquid production through 2050. The CER emphasizes that the report's findings—specifically regarding the electricity sector as the key to decarbonization—should inform the revision of the Integrated Resource Plan for Electricity (IRP 2010).
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Document type: Statement
Thabametsi Power Station, Limpopo Province Motivation for amendment of Environmental Authorisation
This report, prepared by Savannah Environmental (Pty) Ltd for Thabametsi Power Company Proprietary Limited, motivates for amendments to the Environmental Authorisation (EA) of the Thabametsi Coal-Fired Power Station in Limpopo Province. The proposed changes include extending the EA validity, altering the power line corridor, updating property details, and incorporating conditions from a 2016 Ministerial Appeal Resolution.
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Document type: Report
RESPONSE TO MINISTER’S STATEMENT IN RELATION TO THE PROPOSED THABAMETSI & KHANYISA IPP COAL-FIRED POWER STATIONS
A letter from the Life After Coal Campaign and Greenpeace Africa to the South African Minister of Energy, objecting to the proposed Thabametsi and Khanyisa coal-fired independent power producer (IPP) projects. The authors argue that these projects are legally precarious, environmentally damaging, and economically unnecessary compared to renewable energy alternatives.
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Document type: Statement
SUPPLEMENTARY OBJECTIONS TO THE WATER USE LICENCE APPLICATION AND INTEGRATED WATER AND WASTE WATER MANAGEMENT PLAN FOR THE PROPOSED THABAMETSI INDEPENDENT POWER PRODUCER COAL-FIRED POWER STATION
The Centre for Environmental Rights (CER), on behalf of Earthlife Africa Johannesburg and groundWork, submitted supplementary objections on 5 March 2018 against the Water Use Licence Application (IWULA) and Integrated Water and Waste Water Management Plan (IWWMP) for the proposed Thabametsi coal-fired power station. The objections argue that the project is unnecessary due to excess electricity capacity, poses severe risks to the water-stressed Mokolo Catchment, and fails to account for climate change impacts and toxic coal ash disposal risks.
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Document type: Statement
Potential Risks to Water Resources from the Proposed Thabametsi Power Plant
This report evaluates the potential risks to water resources posed by the proposed Thabametsi Power Plant's coal ash dump and pollution control dams. The author concludes that the chosen site is unsuitable and the proposed mitigation measures are insufficient to protect groundwater, surface water, and wetlands.
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Document type: Report
URGENT STEPS NEEDED TO ADDRESS AIR POLLUTION IN THE HIGHVELD PRIORTY AREA
The Centre for Environmental Rights (CER), representing several environmental justice organizations, issued a formal letter to the Director-General of the Department of Environmental Affairs (DEA) on 26 February 2018. The letter demands urgent action to address air pollution in the Highveld Priority Area (HPA), specifically criticizing the DEA's handling of minimum emission standards (MES) compliance, its failure to respond to the 'Broken Promises' report, and the health impacts of emissions from Eskom and Sasol.
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Document type: Statement
DOCUMENTATION FOR MITIGATION PATHWAYS AND ADDITIONAL CLIMATE MITIGATION AND ADAPTATION DOCUMENTS/PROJECTS
The Centre for Environmental Rights (CER) submitted a formal statement to the South African Department of Environmental Affairs on 23 February 2018, requesting clarity on the strategic alignment of various climate mitigation and adaptation documents, including the 'Pathways documents'. The CER expressed concern over the lack of transparency regarding the purpose of these documents and the confidentiality of pollution prevention plans for major emitters, while arguing that climate modelling should reflect research showing that new coal-fired power capacity is unnecessary for South Africa's energy security.
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Document type: Statement
SUBMISSIONS ON THE BACKGROUND INFORMATION DOCUMENT (BID) FOR ESKOM’S SECOND POSTPONEMENT APPLICATION IN RESPECT OF THE 2015 MINIMUM EMISSION STANDARDS (MES) FOR TUTUKA POWER STATION
The Centre for Environmental Rights (CER), on behalf of the Life After Coal campaign and the Highveld Environmental Justice Alliance Network (HEJN), submitted formal objections to Eskom's Background Information Document (BID) regarding a second postponement application for Minimum Emission Standards (MES) at the Tutuka Power Station. The submission argues that the application is legally impermissible because Tutuka is located in the Highveld Priority Area (HPA), where ambient air quality does not comply with National Ambient Air Quality Standards (NAAQS), a prerequisite for any postponement. The CER further contends that Eskom's request for a "rolling postponement" is equivalent to an illegal exemption and that the BID intentionally withholds critical information regarding pollutants, timeframes, and health impacts to mislead the public and decision-makers.
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Document type: Statement
MINISTER’S DECISION TO UPHOLD THE ENVIRONMENTAL AUTHORISATION FOR THE PROPOSED THABAMETSI COAL-FIRED POWER STATION
The Centre for Environmental Rights (CER) has notified the Portfolio Committee on Environmental Affairs of its intention to challenge the Minister of Environmental Affairs' January 30, 2018, decision to uphold the environmental authorisation for the proposed Thabametsi coal-fired power station. The CER argues the decision is unreasonable and unlawful, as it relies on an outdated energy policy to justify a project with very high greenhouse gas emissions and water scarcity risks, contradicting a previous High Court judgment regarding the necessity of independent climate impact assessments.
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Document type: Statement
Peer Review of the Climate Change Study for the Proposed Thabametsi Coal Fired Power Station
This report is a peer review conducted by EOH Coastal & Environmental Services for the Department of Environmental Affairs (DEA) regarding the Climate Change Study and Palaeontological Impact Assessment (CCSPIA) for the proposed 1,200 MW Thabametsi Coal-Fired Power Station. The review evaluates the adequacy of the Greenhouse Gas Assessment (GGA) and the Climate Resilience Assessment (CRA), concluding that while the technical assessments are comprehensive and follow international best practices, there are discrepancies in the overall impact rating and omissions regarding the social cost of carbon.
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Document type: Report
Water Use License Application Report (WULAR) for the Proposed Thabametsi Power Plant within the Lephalale Municipality
This Water Use License Application Report (WULAR) details the water requirements and environmental impact assessments for the proposed 630 MW Thabametsi coal-fired power plant near Lephalale, Limpopo. The report seeks authorization for various water uses under the National Water Act, 1998, including water abstraction, storage, and waste disposal. It emphasizes the use of dry-cooled technology to achieve zero liquid effluent discharge due to regional water scarcity and proposes sourcing water through a permanent transfer of allocation from Exxaro Coal (Pty) Ltd.
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Document type: Report
UPDATE ON THE PREFERRED BIDDERS UNDER THE FIRST BID WINDOW OF THE COAL BASELOAD IPP PROCUREMENT PROGRAMME AND THE PROPOSED KIPOWER COAL-FIRED POWER STATION
The Centre for Environmental Rights (CER), representing Earthlife Africa Johannesburg and groundWork, submitted a letter to the IPP Office of the Department of Energy on 15 September 2017. The letter provides updates on legal and environmental challenges facing three proposed coal-fired power stations: Thabametsi, Khanyisa, and KiPower. The CER argues that these projects fail to meet the legal qualification criteria for financial close or preferred bidder status due to missing climate change impact assessments (CCIA) and pending disputes over environmental and water licenses.
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Document type: Statement
UPDATE ON THE COAL INDEPENDENT POWER PRODUCER (IPP) COAL-FIRED POWER STATIONS – THABAMETSI & KHANYISA
A letter from the Centre for Environmental Rights (CER) to the National Energy Regulator of South Africa (NERSA) providing updates and requesting the status of electricity generation licence applications for the Thabametsi and Khanyisa coal-fired power stations.
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Document type: Statement
THE DEVELOPMENT BANK OF SOUTHERN AFRICA’S ROLE IN THE FINANCING OF THE PROPOSED THABAMETSI COAL-FIRED POWER PLANT
The Centre for Environmental Rights (CER) issued a statement to the Development Bank of Southern Africa (DBSA) expressing alarm over the bank's role in financing the proposed Thabametsi coal-fired power plant. The CER argues that such financing contradicts the DBSA's own sustainability commitments, ignores a landmark court ruling regarding climate change impacts, and exposes the bank to the risk of stranded assets.
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Document type: Statement
RECORD OF RECOMMENDATION: INTEGRATED WATER USE LICENCE FOR KIPOWER IPP COAL-FIRED POWER STATION
The Centre for Environmental Rights (CER), acting on behalf of groundWork, is requesting clarification from the Department of Water and Sanitation regarding the "minimum requirements" used to recommend the issuance of an integrated water use licence (IWUL) for the proposed 600MW KiPower coal-fired power station near Delmas, Mpumalanga.
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Document type: Statement
Thabametsi Power Station Limpopo Province Final Climate Change Study and Palaeontological Impact Assessment COMMENTS AND RESPONSES REPORT
This report documents the responses of Thabametsi Power Company to objections raised by Earthlife Africa and Greenpeace Africa regarding the project's climate change and palaeontological impact assessments. Key points of contention include the project's high GHG emission intensity (1.23 tCO2e/MWh), the failure to quantify the social cost of carbon, and the high risk of water scarcity in the Lephalale region of Limpopo Province. The developer maintains that the project is consistent with South African national energy policy (IRP 2010 and 2016) and that its water needs for Phase 1 are secured through existing allocations from the MCWAP-1 scheme.
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Document type: Report
The proposed KiPower IPP
This case study details legal challenges brought by groundWork and the Centre for Environmental Rights (CER) against the environmental and water authorizations granted for the proposed KiPower coal-fired power station in South Africa.
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Document type: Case study