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Methodology Note for Impacts of Continued Operations of Select Coal-Fired Power Plants and Generating Units
The methodology note describes how the Clean Air Task Force (CATF) models unit-level emissions and resulting health impacts for coal plants slated for retirement between 2025 and 2028. It details the data sources used, the cumulative nature of the map results, and the user-adjustable emission levels provided in the tool.
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Document type: Guide
Appendix A: CCS Costs
The document details CATF's costing approach for CCS retrofits, which utilizes a standalone gas-fired auxiliary boiler for steam to avoid coal plant heat rate penalties, contrasting this with the IPM platform v6's integrated approach. It provides specific capital and operational cost data for 200 MW and 400 MW coal retrofits, as well as NGCC retrofits, noting that while IPM costs favor very large plants through economies of scale, the CATF approach is more favorable for 400 MW units.
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Document type: Statement
appendix_a-95b40c0bef8b6fbb.pdf
The document argues that post-combustion carbon capture is a mature technology capable of achieving capture rates of 90% to 99% for coal and natural gas power plants. It provides evidence from existing operational plants, ongoing FEED studies, and techno-economic modeling to demonstrate that CCS is economically viable, particularly when supported by the U.S. 45Q tax credit. The report also details the availability of vast geologic storage capacity in saline aquifers and the existing regulatory framework for safe CO2 injection. Additionally, it examines co-benefits such as the reduction of SO2 and NOx emissions, the impact of different cooling technologies on water consumption, and the operational flexibility of CCS-equipped plants.
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Document type: Report
catf_whitepapers_draftnotificationonairemissionstandards_tables-92a15d24f44dd510.pdf
The document contains technical tables comparing proposed Indian coal power plant emission standards for SO2, NOx, and PM with standards from the EU, China, and the US. It also includes detailed performance data for numerous US coal units, specifically listing SO2 and NOx rates for 2014, as well as tested levels of filterable particulate matter and mercury across various plants.
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Document type: Report
Haze in our National Parks
The report identifies power plants as the primary source of sulfate particles causing regional haze in U.S. national parks, which significantly reduces visibility and diminishes visitor enjoyment. An analysis by Abt Associates estimates that eliminating power plant haze would provide a total annual benefit of $7.7 billion, comprising $4.3 billion in recreational visibility and $3.4 billion in residential visibility. The document highlights that improved visibility could increase park visitation by 10% to 25%, generating hundreds of millions of dollars in revenue and thousands of jobs for local communities. It recommends the implementation of 'best available retrofit technology' (BART) and a shift toward natural gas and renewable energy to achieve the national goal of remedying visibility impairment.
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Document type: Report
reliability-only_dispatch-927634c73b3e6c63.pdf
The report examines the public health and environmental impacts of delaying compliance with the Air Toxics Rule for coal- and oil-fired power plants. It proposes a 'Reliability-Only Dispatch' mechanism, which would restrict units granted compliance extensions to operate only when absolutely necessary for grid reliability, rather than allowing 'business as usual' operations. Using modeling and case studies like the Cromby-Eddystone agreement, the author argues this approach can significantly reduce premature deaths and health damages compared to unrestricted extensions.
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Document type: Report
Comments on the series of Applications for Suspension of the Minimum Emissions Standards (MES) Compliance Timeframes for Various Eskom Coal-Fired Power Plants
The document argues that Eskom's justifications for delaying emissions compliance—including plant decommissioning, water scarcity, and high costs—are untenable. The author contends that Eskom's capital expenditure estimates for air pollution controls are substantially inflated compared to similar projects in India and suggests alternative, lower-cost technologies like Dry Sorbent Injection (DSI) and Selective Non-catalytic Reduction (SNCR) to achieve emissions reductions.
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Document type: Legal commentary
Comments on the Proposed Increase in the Minimum Emission Standard (MES) for Sulphur Dioxide (SO2) Applicable to Coal-Fired Power Plant Stacks in South Africa
The report argues against doubling the SO2 emission limit, asserting that the government's rationale regarding water use and cost is flawed. It contends that Flue Gas Desulfurization (FGD) is more effective and not prohibitively water-intensive, while Dry Sorbent Injection (DSI) poses significant risks to particulate matter control, mercury emissions, and groundwater quality. The author recommends reducing the MES to 200 mg/Nm3 to align with international norms.
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Document type: Report
Medupi Flue Gas Desulphurisation: Technology Selection Study Report
The report evaluates Wet FGD and Dry FGD (specifically Circulating Fluidized Bed - CFB) technologies for the Medupi Power Station. It recommends the implementation of Wet FGD without a flue gas cooler, citing its superior cost-efficiency, technical maturity, and potential to support local socio-economic development through the use of regional limestone.
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Document type: Report
annexure-e-groundwork-authorisation-bad16d432cba2c85.pdf
A letter dated 6 September 2017 from Sven Eaton Patrick Peck, Director of groundWork, appointing the Centre for Environmental Rights (CER) as attorneys of record to represent groundWork in an appeal to the Water Tribunal regarding a water use licence for the proposed KiPower 600MW coal-fired power station.
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Document type: Statement
KM_C654e-20170203144023
The South African Department of Environmental Affairs issued an amendment to the Environmental Authorisation (EA) dated 31 October 2013 for the construction of the 450 MW Khanyisa coal-fired power station in Emalahleni, Mpumalanga. The amendment updates the project applicant and the specific farm portions designated for the project site and ash disposal site.
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Document type: Statement
Health impacts of Eskomʼs non-compliance with minimum emissions standards
The report finds that Eskom's current retrofit plan is insufficient to address sulphur dioxide (SO2) emissions, leading to significant projected mortality and economic losses. Full compliance with the MES by 2025 would avoid approximately 2,300 deaths and R42 billion in economic costs annually. The most stringent scenario, applying Best Available Technology (BAT), would reduce health impacts by over 90% by 2031 compared to the current plan.
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Document type: Report
Air Quality, Health, and Economic Impacts of a New Coal Mine and Power Plant in Lephalale
The report finds that the proposed Lephalale Coal Mine (LCM) and its power plant will cause significant air quality violations and severe health and economic burdens. It argues that a previous environmental impact assessment (EIA) by GESI (2017) underestimated these impacts by neglecting mercury, existing pollution sources, and secondary PM2.5 formation. The analysis indicates that while mining alone causes 93 premature deaths, burning the coal on-site increases this to 3,120 deaths, and burning it at existing plants like Medupi or Matimba could lead to up to 41,984 premature deaths. Mercury emissions are projected to cause a loss of 3,700 IQ points and 554 lives, with significant deposition in protected ecosystems like the Waterberg Biosphere Reserve.
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Document type: Report
IRP Factsheet English Final
The document outlines the South African government's Integrated Resource Plan (IRP) and a September 2020 determination to procure 1500MW of new coal-fired electricity from independent power producers. It argues that this decision negatively impacts public health, the climate, and electricity costs, while advocating for a transition to cheaper, cleaner renewable energy sources.
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Document type: Fact sheet
THE MYTH OF “CLEAN COAL”
The document asserts that "clean coal" is impossible, as the entire coal cycle—from mining to combustion—causes severe damage to health, water, and the climate. It critiques three specific technologies: High Efficiency, Low Emissions (HELE) plants, which only reduce CO2 by up to 20% while increasing costs; Circulating Fluidised Bed (CFB) systems, which increase solid waste and N2O emissions; and Carbon Capture and Storage (CCS), which remains unproven in South Africa and faces high costs and geological transport challenges. The text highlights that Eskom and Sasol are primary coal users in South Africa, and that wind and solar power are cleaner, cheaper alternatives.
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Document type: Fact sheet
response-to-cer-letter-15-sep-17-111017-370dbb5fc85ad0a3.pdf
This document consists of correspondence from the Independent Power Producer (IPP) Office to the Centre for Environmental Rights regarding the Coal Baseload IPP Procurement Programme, specifically addressing preferred bidders for the Thabametsi, Khanyisa, and KiPower coal-fired power stations.
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Document type: Statement
scanned-from-a-xerox-multifunction-printer-278dd015871594fa.pdf
This document is a legal response submitted by ACWA Power Khanyisa Thermal Power Station (RF) (Pty) Ltd (ACWA) to the Minister of Environmental Affairs. ACWA objects to a condonation application by the NGO Groundwork, which seeks to appeal the integrated environmental authorisation for the Khanyisa Thermal Power Station. ACWA argues that Groundwork's notice of intention to appeal was filed excessively late and that the legal justifications provided—specifically the reliance on the Thabametsi judgment regarding climate change assessments—are legally unsound.
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Document type: Report
KM_C654e-20160826132125
A letter from the South African Department of Environmental Affairs approving an amendment to the Environmental Authorisation (EA) for the 1200MW Thabametsi coal-fired power station, specifically updating the designated holder of the authorisation.
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Document type: Statement
duvha-power-station-_-particulate-emission-correlation-ba94680f1a0778ce.pdf
The document analyzes particulate emission data from the Duvha Power Station, specifically examining the correlation between emission levels and the operational status of its power units. It evaluates whether emissions are caused by the units themselves or by other factors, such as the operation of the electrostatic precipitators (ESP) and the overall plant configuration.
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Document type: Report
CENTRE FOR ENVIRONMENTAL RIGHTS: HEADS OF ARGUMENT
The Centre for Environmental Rights (CER) argues that South African local governments must be empowered to procure renewable energy to meet constitutional obligations under Section 24 of the Constitution, which guarantees the right to a healthy environment. The CER contends that the current reliance on Eskom's coal-fired power stations causes significant health crises, including thousands of premature deaths and high greenhouse gas emissions. It asserts that renewable energy is now the most cost-effective option and that interpreting the Electricity Regulation Act (ERA) to allow municipal procurement is essential for a just energy transition and the realization of sustainable development.
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Document type: Legal commentary