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COMMENTS ON THE DRAFT SCOPING REPORT FOR THE PROPOSED MOKOLO AND CROCODILE RIVER (WEST) WATER AUGMENTATION PROJECT (PHASE 2)
The Centre for Environmental Rights (CER), acting for Earthlife Africa NPC and groundWork, submitted comments on 11 April 2018 regarding the draft Scoping Report for the Mokolo and Crocodile River (West) Water Augmentation Project (Phase 2) (MCWAP-2). The CER argues that the project is based on outdated assumptions regarding South Africa's energy needs and fails to adequately assess climate change, water reserves, and indirect environmental and health impacts.
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Document type: Statement
OBJECTIONS TO GENERATION LICENCE APPLICATIONS FOR THABAMETSI AND KHANYISA IPP COAL-FIRED POWER STATIONS
The Centre for Environmental Rights (CER), representing Earthlife Africa and groundWork, submitted a formal letter to the National Energy Regulator of South Africa (NERSA) on 4 April 2018. The letter follows a public hearing held on 27 March 2018 regarding generation licence applications for the Thabametsi and Khanyisa coal-fired power stations, raising concerns about the hearing process and requesting further information on NERSA's procedural compliance.
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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
Report on Thabametsi Mine and Power Plant Modeling
Air dispersion modeling by Dr. Ranajit Sahu indicates that the proposed Thabametsi power plant and mine, combined with existing facilities like Matimba and Medupi, would likely cause air pollution levels (specifically SO2, NOx, and PM2.5) to exceed South Africa's National Ambient Air Quality Standards. The report highlights significant underestimations of PM emissions from the mine in previous assessments and notes a critical lack of accurate local air monitoring data.
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Document type: Report
PUBLIC HEARINGS IN RESPECT OF THE GENERATION LICENCE APPLICATIONS FOR THE PROPOSED KHANYISA AND THABAMETSI INDEPENDENT POWER PRODUCER COAL-FIRED POWER STATIONS
The Centre for Environmental Rights (CER) submitted a letter to the National Energy Regulator of South Africa (NERSA) on 6 March 2018, requesting procedural details for public hearings regarding generation licence applications for the proposed Khanyisa and Thabametsi coal-fired power stations.
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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
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
RELEVANT INFORMATION IN RELATION TO THE DRAFT INTEGRATED RESOURCE PLAN FOR ELECTRICITY UPDATE & THE DRAFT INTEGRATED ENERGY PLAN
The Centre for Environmental Rights (CER), representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted a formal statement to the Portfolio Committee on Energy on 29 November 2017. The document outlines critical concerns regarding the lack of transparency, inadequate public consultation, and the omission of key economic and environmental data in the development of South Africa's draft Integrated Resource Plan (IRP) for Electricity Update and the draft Integrated Energy Plan (IEP).
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Document type: Statement
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
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
Thabametsi Power Station Limpopo Province Climate Change Study and Palaeontological Impact Assessment
This report presents the results of a climate change study, a climate resilience assessment, and a palaeontological impact assessment for the proposed 1200MW Thabametsi coal-fired power station near Lephalale in Limpopo Province, South Africa. The document evaluates the project's greenhouse gas (GHG) emissions, its vulnerability to future climate scenarios, and the potential for fossil material destruction during construction.
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Document type: Report
APPEAL PURSUANT TO SECTION 43(2) OF THE NATIONAL ENVIRONMENTAL MANAGEMENT ACT, 1998 AGAINST ENVIRONMENTAL AUTHORISATION GRANTED TO NAMANE GENERATION (PTY) LTD ON 28 FEBRUARY 2017
An appeal by Earthlife Africa Johannesburg and groundWork to set aside the environmental authorisation for the 660 MW Namane coal-fired power station in Limpopo, South Africa. The appellants argue the decision is unlawful due to failures to assess climate change impacts, air quality risks, and water scarcity in the Waterberg region, while ignoring renewable energy alternatives and violating national and international environmental commitments.
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Document type: Statement
SUBMISSIONS ON DRAFT CLIMATE CHANGE IMPACT ASSESSMENT REPORT FOR THABAMETSI IPP COAL-FIRED POWER STATION
The Centre for Environmental Rights, acting for Earthlife Africa Johannesburg, submitted comments on the draft Climate Change Impact Assessment (CCIA) and Palaeontological Impact Assessment (PIA) for the proposed Thabametsi coal-fired power station. The submission argues that the draft CCIA significantly underestimates greenhouse gas emissions, ignores the social cost of carbon, and fails to adequately address severe water scarcity risks in the Lephalale area. The authors contend that the project is not in the national interest due to existing excess energy capacity and that the most appropriate recommendation is a 'no go option' to avoid irreversible environmental and social harm.
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Document type: Statement
OBJECTIONS TO THE INTEGRATED WATER USE LICENCE APPLICATION FOR PROPOSED IPP THABAMETSI POWER STATION
The Centre for Environmental Rights, acting for Earthlife Africa Johannesburg, submitted formal objections on 20 January 2017 to the Integrated Water Use Licence Application (IWULA) for the proposed 1200MW coal-fired Thabametsi power station near Lephalale, Limpopo. The submission argues that the application is fatally flawed due to outdated data, failure to account for climate change, risks to groundwater and wetlands, and a lack of guaranteed water availability for the project's 40-year lifespan.
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Document type: Statement
COAL-FIRED POWER STATION AND ASSOCIATED INFRASTRUCTURE - IPP WATERBERG (THABAMETSI) POWER STATION NEAR LEPHALALE (DEA Ref No: 14/12/16/3/3/40) LIMPOPO PROVINCE CLIMATE CHANGE STUDY AND PALAEONTOLOGICAL IMPACT ASSESSMENT: SUMMARY REPORT FOR PUBLIC REVIEW
This summary report, prepared by Savannah Environmental (Pty) Ltd for Thabametsi Power Company Proprietary Limited, details the climate change and palaeontological impact assessments for the proposed 1200MW Thabametsi coal-fired power station near Lephalale, Limpopo Province. The report was produced to satisfy conditions 10.5 and 10.6 of the project's Environmental Authorization following an appeal by the Centre for Environmental Rights. It evaluates greenhouse gas (GHG) emissions, climate resilience risks, and potential impacts on fossil heritage, concluding that while GHG impacts are high, they are not a fatal flaw given South Africa's energy policy framework.
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Document type: Report
RECOMMENDATIONS FOR THE CLIMATE CHANGE IMPACT ASSESSMENT TO BE CONDUCTED BY THABAMETSI POWER PROJECT (PTY) LTD
The Centre for Environmental Rights (CER), on behalf of Earthlife Africa Johannesburg, provides recommendations to improve the scope of the Climate Change Impact Assessment (CCIA) and Palaeontological Impact Assessment Report (PIAR) for the proposed 1200MW Thabametsi coal-fired power station near Lephalale, Limpopo. The CER argues that the current scoping report is too narrow and fails to align with international best practices or South Africa's climate commitments under the Paris Agreement and its Intended Nationally Determined Contribution (INDC).
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Document type: Statement
Water: Facts and Futures
WWF South Africa's 2016 report 'Water: Facts and Futures' details the critical state of the country's water security. It highlights that while only 8% of land generates 50% of river flow, these Water Source Areas are under-protected. The report identifies severe threats from invasive alien plants, failing engineered infrastructure (with 37% urban water loss), and widespread pollution from sewage and mining. It calls for a 'Water and Sanitation Revolution' focusing on nature-based solutions, groundwater management, and decentralized service delivery to ensure equitable access to safe water.
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Document type: Report
DECISION ON THE APPEAL OF THE AMENDED ENVIRONMENTAL AUTHORISATION GRANTED TO NEWSHELF 1282 (PTY) LTD FOR THE PROPOSED THABAMETSI POWER STATION
A letter from the Centre for Environmental Rights (CER), acting for Earthlife Africa Johannesburg, to Gunn Attorneys regarding the appeal decision for the Thabametsi power station. The CER seeks clarification on the implementation of new conditions for climate change and paleontological assessments and disputes the lawfulness of the decision.
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Document type: Statement