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RESPONSE TO NERSA LETTER OF 14 NOVEMBER 2017 – RELEVANT INFORMATION IN RELATION TO THABAMETSI AND KHANYISA IPP POWER STATION PROJECTS
The Centre for Environmental Rights (CER), acting for Earthlife Africa Johannesburg and groundWork, wrote to the National Energy Regulator of South Africa (NERSA) on 5 December 2017 regarding licensing applications for the Thabametsi and Khanyisa coal-fired power stations. The letter challenges NERSA's handling of the applications, highlighting outstanding water use licences (WUL), atmospheric emission licences (AEL), and ongoing court reviews.
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Document type: Statement
BROKEN PROMISES
This October 2017 report by the Centre for Environmental Rights, groundWork, and the Highveld Environmental Justice Network evaluates the failure of the Highveld Priority Area (HPA) to improve air quality in South Africa. Despite the 2007 declaration of the HPA and the 2012 Air Quality Management Plan (AQMP), the report concludes that air quality remains poor and non-compliant with health-based standards, largely due to industrial emissions, inadequate monitoring, and a lack of government capacity and enforcement.
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Document type: Report
IMPLICATIONS OF THE JUDGMENT IN EARTHLIFE AFRICA JOHANNESBURG V MINISTER OF ENVIRONMENTAL AFFAIRS AND OTHERS CASE NO 65662/16
A letter from the Centre for Environmental Rights to the South African Department of Environmental Affairs regarding the legal implications of the North Gauteng High Court judgment in Earthlife Africa Johannesburg v Minister of Environmental Affairs and Others (the Thabametsi case).
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Document type: Statement
UPDATE ON THE THABAMETSI POWER COMPANY (PTY) LIMITED AND ACWA POWER KHANYISA THERMAL POWER STATION (RF) (PTY) LIMITED INDEPENDENT POWER PRODUCER PROJECTS
The Centre for Environmental Rights (CER), representing Earthlife Africa Johannesburg and groundWork, sent a letter to the South African Department of Energy's IPP Office on 6 April 2017. The letter alerts the Department that two preferred bidders under the Coal Baseload Independent Power Producer Procurement Programme (CBIPPPP)—Thabametsi Power Company and ACWA Power Khanyisa—appear unable to meet the legal qualification criteria for financial and commercial close due to missing or contested environmental and generation licenses.
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Document type: Statement
REQUEST FOR COPIES OF THE LATEST: EMISSION REDUCTION PLANS, COMPLIANCE ROADMAPS, AND DECOMMISSIONING SCHEDULE AND PLANS FOR ALL 15 OF ESKOM’S COAL FIRED POWER STATIONS
The Centre for Environmental Rights (CER), acting on behalf of several environmental organizations, issued a formal request to Eskom on 25 April 2016 for emission reduction plans, compliance roadmaps, and decommissioning schedules for all 15 of its coal-fired power stations. The CER asserts that existing compliance roadmaps provided by the National Air Quality Officer (NAQO) are insufficient to ensure Eskom meets the emission standards set in its atmospheric emission licences (AELs) and the minimum emission standards (MES).
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Document type: Statement
APPEAL IN TERMS OF SECTION 62 OF OF THE LOCAL GOVERNMENT: MUNICIPAL SYSTEMS ACT, 2000 OF ESKOM’S KOMATI POWER STATION ATMOSPHERIC EMISSION LICENCE 17/4/AEL/MP313/12/12 ORIGINALLY ISSUED ON 31 MARCH 2015
The Centre for Environmental Rights, representing environmental justice organisations, appealed the Atmospheric Emission Licence (AEL) for Eskom's Komati Power Station. The appeal argues that the AEL illegally allows Eskom to exceed national Minimum Emission Standards (MES) for NOx and SO2, ignoring the critical air quality failure in the Highveld Priority Area and the resulting health impacts on the population.
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Document type: Statement
DECISION ON APPLICATIONS FOR POSTPONEMENT OF COMPLIANCE TIME-FRAMES FOR MINIMUM AIR QUALITY EMISSION STANDARDS: REQUEST FOR CLARIFICATION
The Centre for Environmental Rights (CER) sent a letter to the National Air Quality Officer (NAQO) on 7 April 2015 requesting urgent clarification on decisions regarding Eskom's applications to postpone compliance with minimum air quality emission standards (MES). The CER identifies numerous discrepancies between Eskom's applications and the final decisions regarding postponement periods and emission limits for various pollutants, including particulate matter (PM), sulphur dioxide (SO2), and nitrogen oxides (NOx).
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Document type: Statement
ADDITIONAL SUBMISSIONS ON ESKOM’S APPLICATIONS FOR POSTPONEMENT OF COMPLIANCE WITH THE MINIMUM EMISSION STANDARDS IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT: AIR QUALITY ACT, 2004: FOCUSSING ON ESKOM’S RESPONSES REGARDING HEALTH IMPACTS, FUTURE COMPLIANCE AND MONITORING DATA
The Centre for Environmental Rights (CER) submitted a statement to the Department of Environmental Affairs (DEA) opposing Eskom's applications to postpone compliance with Minimum Emission Standards (MES). The CER argues that Eskom failed to provide required health impact assessments and future compliance plans, while monitoring data indicates that Eskom's emissions cause frequent, year-round exceedances of air quality guidelines, contributing to significant regional health risks.
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Document type: Statement
SUBMISSIONS ON ESKOM’S APPLICATIONS FOR POSTPONEMENT OF COMPLIANCE WITH THE MINIMUM EMISSION STANDARDS IN TERMS OF THE NATIONAL ENVIRONMENTAL MANAGEMENT: AIR QUALITY ACT, 2004
The Centre for Environmental Rights (CER), representing several community and environmental groups, submitted preliminary representations opposing Eskom's applications to postpone compliance with Minimum Emission Standards (MES) for its coal-fired power stations. The CER argues that Eskom's applications are based on flawed atmospheric modelling, exaggerated compliance costs, and a failure to meet the legal requirements of the National Environmental Management: Air Quality Act (AQA) and the 2012 National Framework for Air Quality Management. The submission highlights that granting these postponements would increase pollution in declared Priority Areas and cause significant detrimental impacts on human health.
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Document type: Report
ESKOM SOC HOLDINGS LTD’S (ESKOM) APPLICATION TO POSTPONE COMPLIANCE WITH AND/OR BE EXEMPT FROM MINIMUM EMISSION STANDARDS FOR SULPHUR DIOXIDE (SO2), NITROGEN OXIDES (NOX), AND PARTICULATE MATTER (PM) FOR ITS POWER STATIONS
The Centre for Environmental Rights (CER), representing several community and environmental groups, submitted a letter to the South African Minister of Water and Environmental Affairs and the National Air Quality Officer. The letter challenges Eskom's applications to postpone or be exempt from Minimum Emission Standards (MES) for sulphur dioxide, nitrogen oxides, and particulate matter across 17 power stations, arguing that the current application process lacks necessary health risk assessments and adequate public participation.
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Document type: Statement
ESKOM’S APPLICATION FOR EXEMPTION FROM MINIMUM EMISSION STANDARDS AND POSTPONEMENT OF THE MINIMUM EMISSION STANDARDS TIMEFRAMES FOR ESKOM POWER STATIONS
The Centre for Environmental Rights (CER), representing several community and environmental groups, submitted comments on August 23, 2013, regarding uMoya-NILU Consulting's Plan of Study (PoS). The PoS was designed to support Eskom's applications for exemptions and postponements of Minimum Emission Standards (MES) for its power stations. The CER argues that the PoS is too narrow in scope, fails to include critical pollutants like PM2.5, uses inappropriate modelling software for near-field impacts, and lacks a mechanism to verify model outputs against real-world ambient measurements.
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Document type: Statement
Monitoring airborne dust in a high-density coal-fired power station region in North Yorkshire
A two-year monitoring study in North Yorkshire investigated dust deposition in villages near coal-fired power stations, specifically focusing on the impact of Drax Power Station and its fly-ash tip on the village of Barlow.
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Document type: Research paper
161107-eskom-grounds-of-appeal-3341d66da8c1ef49.pdf
This document is an internal appeal submitted by groundWork, represented by the Centre for Environmental Rights (CER), against the deemed refusal by Eskom Holdings SOC Limited to provide records regarding its compliance with emission standards and the decommissioning of its coal-fired power stations.
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Document type: Statement
5-generation-fleet-renewal-db68f755d81b0ef0.pdf
This document is a Task Order (No. 598) issued by Eskom for engineering and project management services to conduct a pre-feasibility study on a 'fleet renewal strategy' for four specific coal-fired power stations. The study aims to evaluate alternatives to the current decommissioning strategy, which is based on a 60-year technical life for coal stations.
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Document type: Briefing
annexure-1_cer-letter-to-aqos-cbb5f4cebd2ec54b.pdf
A letter from the Centre for Environmental Rights (CER) to various South African licensing authorities regarding the variation of Eskom's Atmospheric Emission Licences (AELs) following the granting of postponements for compliance with Minimum Emission Standards (MES).
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Document type: Statement
annexure-b-1-ae05ca5f3c13a16f.pdf
A letter from the Centre for Environmental Rights (CER) to the South African Minister of Health, requesting the Department of Health's participation in the Highveld Priority Area (HPA) Multi-Stakeholder Reference Group meetings to address the severe health impacts of air pollution.
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Document type: Statement
annexure-d_gem09_l019_emission_standards_compliance_timeframes_mar09-1-979b3ed0e8512e11.pdf
A letter from Eskom to the South African Bureau of Standards (SABS) detailing the company's position on compliance timeframes for proposed Minimum Emission Standards for its coal-fired power stations.
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Document type: Statement
annexure-h_eskoms-response-to-deas-additonal-information-request-in-terms-of-the-postponement-applications_camden-power-station-4cfac5ed4422baee.pdf
This document is a response from Eskom to the Department of Environmental Affairs (DEA) regarding a request for additional information on the postponement application for the Camden Power Station to comply with Minimum Emission Standards (MES). Eskom states that the station will not comply with 'new plant' standards for particulate matter (PM), sulfur dioxide (SO2), or nitrogen oxides (NOx) before its expected decommissioning between 2020 and 2023.
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Document type: Briefing
annexure-h_eskoms-response-to-deas-additonal-information-request-in-terms-of-the-postponement-applications_hendrina-power-station-d57cbbdc7c872fea.pdf
This briefing, dated 17 July 2014, is a response from Eskom to the South African Department of Environmental Affairs (DEA) regarding a postponement application for the Hendrina Power Station to comply with Minimum Emission Standards (MES). Eskom outlines current stack emission limits, its lack of plans to upgrade the station for certain pollutants, and provides ambient air quality monitoring data showing non-compliance for particulate matter.
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Document type: Briefing
annexure-h_eskoms-response-to-deas-additonal-information-request-in-terms-of-the-postponement-applications_lethabo-power-station-8abc67952e171fd4.pdf
This document is a letter from Eskom to the Department of Environmental Affairs (DEA) dated 17 July 2014, providing additional information to support a postponement application for the Lethabo Power Station's compliance with Minimum Emission Standards (MES). Eskom outlines current stack emission limits, argues that full compliance by 2015 and 2020 is not practically feasible, and provides ambient air quality monitoring data and a register of public complaints regarding pollution.
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Document type: Briefing